In response to the coronavirus (COVID-19) emergency and potential liquidity issues for registered funds, the SEC has provided temporary relief to allow registered funds to sell assets to, and borrow from, their affiliates in transactions that would otherwise have been prohibited. This relief includes additional flexibility involving interfund lending and borrowing facilities within multi-fund complexes.
Fund directors will need to consider a variety of factors when weighing these options to address their funds’ current or potential liquidity needs. In this audiocast, the SEC relief and considerations for fund directors were discussed by Nora Jordan, the head of Davis Polk’s Investment Management Group; Greg Rowland, a partner in the group; and Aaron Gilbride, who joined the group as counsel last year after several years in the SEC’s Division of Investment Management.
Related content on Davis Polk Coronavirus Updates includes:
Client Alert, March 24, 2020
Client Alert, March 16, 2020