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On October 29, 2026, the Staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “SEC”) issued a no-action letter to Goldman Sachs Asset Management, L.P. (“GSAM”) addressing warehouse arrangements entered into in connection with the launch of registered closed-end funds and business development companies (“BDCs”).  The letter confirms…

On October 9, 2026, the Securities and Exchange Commission proposed amendments to Rule 17a-7 under the Investment Company Act of 1940, as amended, that would expand the types of securities eligible for cross trading between registered investment companies (“registered funds”) and certain affiliated persons. The proposed amendments are a welcome development for the industry, and…

On September 30, 2026, the Securities and Exchange Commission (the “SEC”) issued two proposing releases containing amendments that would materially affect how business development companies (“BDCs”) that have elected to be regulated under the Investment Company Act of 1940, interval funds and other registered funds are structured, as well as their compensation and distribution models.…

On September 30, 2026, the Securities and Exchange Commission (the “SEC”) proposed amendments intended to provide additional flexibility for regulated funds and their investment advisers.  The proposals address performance-based compensation, interval fund repurchase requirements and multiple share classes for registered closed-end funds and business development companies (“BDCs”).  The SEC also separately requested comment on potential…

The Securities and Exchange Commission (“SEC”) announced an open meeting to be held on September 30, 2026.  The SEC will consider several matters relating to investment advisers, closed-end funds and business development companies and accredited investors.

The SEC will first consider whether to propose amendments to the rule under the Investment Advisers Act of 1940…

Yesterday, on September 1, the Securities and Exchange Commission wrapped up what has been a very busy summer by proposing amendments to the rules and forms governing registered transfer agents.  If adopted, this will be the first significant update to this regulatory framework in over four decades, a change many believe is long overdue.  As…

On June 18, 2026, the Securities and Exchange Commission (“SEC”) granted conditional exemptive relief (the “Conditional Exemption”) from the central clearing mandate for U.S. Treasury securities for private funds to access central clearing through captive clearing subsidiaries.

SEC Rules 17ad-22(a) and (e)(18)(iv)(A) require a U.S. Treasury securities covered clearing agency (“U.S. Treasury securities CCA”) to…

On May 19, 2026, the SEC released two proposed rule amendments aimed at modernizing the registered offering framework and simplifying ongoing reporting obligations for public companies.  The economic analysis accompanying the “Registered Offering Reform” proposal provides a detailed snapshot of the current landscape for business development companies (“BDCs”) and closed-end funds (“CEFs”), including…

On March 27, 2026, the Securities and Exchange Commission (“SEC”) announced its intention to adjust the dollar thresholds used under the Investment Advisers Act of 1940 in determining when a registered investment adviser may charge performance‑based fees.  These fees, which tie adviser compensation to investment gains, are generally prohibited except in respect of “qualified clients”…