Title

SEC Proposes Significant Changes to Rules for Funds of Funds
Client Memorandum

Created date

1/22/2019

In late December, the SEC proposed changes it said would “streamline and enhance the regulatory framework applicable to funds that invest in other funds.” The proposal would rescind Rule 12d1-2 and most funds-of-funds-related exemptive orders and instead provide a new framework for funds of funds under a new Rule 12d1-4. Our client memo examines the scope of the proposed rule and what the changes would mean in areas including voting, redemptions and fees.