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Client Alerts
Dec. 17, 2015

Special Update on Proposed Derivatives Rules for Registered Funds and BDCs

At an open meeting on December 11, 2015, the Securities and Exchange Commission ("SEC") proposed a new "exemptive" rule, Rule 18f-4, which addresses investment company use of derivatives and other leveraging arrangements. It would require most funds that use derivatives to implement a derivative risk management program (including appointing a derivatives management officer). The proposed rule applies to mutual funds, ETFs, closed-end funds and BDCs.

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