SEC Proposes New Limits on Registered Funds’ Derivatives Use
Client Memorandum

Created date


On December 11, 2015, the U.S. Securities and Exchange Commission proposed Rule 18f-4, which would impose new exposure limits, asset segregation requirements, and compliance obligations on registered investment companies and business development companies (“registered funds”) that enter into derivatives transactions or financial commitment transactions. The proposal also would amend previously proposed regulatory reporting forms, Forms N-PORT and N-CEN, to require additional reporting by registered funds about their derivatives activities and financial commitment transactions.