IM Staff Withdraws Letters Issued Prior to Adoption of Derivatives Rule

The SEC’s Division of Investment Management released a staff statement regarding withdrawal and modification of staff letters related to rulemaking on use of derivatives and certain other transactions in light of the adoption of rule 18f-4 under the 1940 Act. Consistent with the adopted rule and the discussion in the related release, the staff is withdrawing staff statements relating to section 18 and section 12(a) of the 1940 Act included in staff letters and a staff issue of interest effective as of August 19, 2022. On May 24, the MFDF will host a webinar on the fund board’s role in overseeing a fund’s derivatives risk management program and compliance with the new Rule 18-f-4. Registration is available here.