Hello dear readers. If you are reading this today, on April 1, and you have a December 31 fiscal year end, then you have survived your annual Form ADV amendment. Congratulations! And while many of you are doubtless gearing up for an annual Form PF filing due at the end of this month, you might
SEC Staff Grants Limited No-Action Relief Regarding the In-Person Board Meeting Requirement under the Investment Company Act
On February 28, 2019, the staff of the SEC’s Division of Investment Management granted no-action relief in connection with the 1940 Act’s in-person meeting requirements under Section 15 of the Investment Company Act of 1940 (the “1940 Act”). This relief would apply to the boards of directors of a registered investment companies (each a “fund”) and would permit them to, under certain delineated circumstances, approve certain investment advisory and principal underwriting contracts of a fund, the 12b-1 plan of a fund and the selection of a fund’s independent public accountant telephonically, either by video conference or by other means by which all participating directors may participate and communicate with each other simultaneously during a meeting.
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