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
Investment Company Act
Petition Requests Amendments to “Qualified Purchaser” and “Qualified Institutional Buyer” Definitions
On May 1, 2026, the Private Investor Coalition, Inc. (“PIC”) submitted a rulemaking petition to the Securities and Exchange Commission (the “SEC”) requesting amendments to the definitions of “qualified purchaser” (as defined in Section 2(a)(51) of the Investment Company Act of 1940 (the “Investment Company Act”)) and “qualified institutional buyer” (“QIB”) (as defined in Rule…
Skip the Misery: Modernize Fund Rules
On March 24, 2026, Securities and Exchange Commission Commissioner Hester Peirce spoke at the Investment Company Institute’s 2026 Investment Management Conference laying out a pragmatic path to modernize the fund regulatory framework. Her remarks emphasized that many of the industry’s longstanding pain points are well understood and, in some cases, readily fixable. Among several key…
SEC Grants No-Action Relief to Registered Investment Advisers and Certain Registered Investment Companies to Treat a State Trust Company Providing Crypto Asset Custody Services as a “Bank”
On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”); and (ii) investment companies registered under the Investment Company Act of…
House Committee on Financial Services Advances Capital Formation Legislation
On July 22 and 23, 2025, the House Committee on Financial Services (the “Committee”) held a full committee markup during which it considered certain bills that, if passed, would improve investor access to the capital markets. These bills have been ordered to be reported to the House of Representatives (the “House”) for consideration. While there…
Co-Investment Relief a Step to Retail Access to Registered Funds
On March 4, 2025, the Investment Company Institute (ICI) wrote to the Securities and Exchange Commission (SEC) to express its support of a request for co-investment exemptive relief by an applicant and urge that the SEC grant similar class relief on a go-forward basis. In brief, Section 17(d) of the Investment Company Act of 1940…
Managed Funds Association Publishes Letter to SEC Acting Chair Mark Uyeda
The Managed Funds Association (MFA) published a letter dated January 20, 2025, to Acting Chair Mark T. Uyeda of the US Securities and Exchange Commission, outlining several policy recommendations for the SEC’s consideration.
The MFA urged the SEC to withdraw its appeal of the “Dealer Rule,” which was vacated by the US District Court of…
Qualifying Venture Capital Funds Inflation Adjustment
The Securities and Exchange Commission adopted Rule 3c-7, which adjusts for inflation the dollar threshold used in defining a “qualifying venture capital fund” under the Investment Company Act, as required pursuant to Section 504 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (“EGRRCPA”). The final rule allows the SEC to adjust…

