| Suspending requirements of In-person Board Meetings | An in-person board meeting is not required for the board of a relying fund to enter into, renew or materially amend investment advisory contracts, underwriting and distribution agreements and Rule 12b-1 plans, and select its independent public accountant. | Reliance on the relief is necessary or appropriate due to circumstances related to current potential effects of COVID-19 (some boards have been approving a resolution to this effect at the non-in-person meeting). | Required. A relying fund’s board must ratify the actions taken pursuant to the exemptive relief at its next in-person meeting. | None. | August 15, 2020 |
| Filing Deadlines extended for Form N‑CEN, Form N‑PORT and Annual and Semi-Annual Reports | A relying fund may delay filing its Form N-CEN and Form N-PORT filings and annual and semi-annual reports past the deadlines required by Section 30(e) and Rule 30e-1 thereunder. | A relying fund must file the applicable reports as soon as practicable, and must do so no later than 45 days after the original due date. | Not required. | Prompt disclosure on the relying fund’s website and notice to SEC staff at [email protected] stating intent to rely on the relief. With respect to Form N‑CEN and Form N‑PORT, the form eventually filed must include a statement of the filer stating it relied on the relief and the reason it was unable to file such report on a timely basis. | June 30, 2020 |
| Delayed Delivery of Fund Prospectuses for Subsequent Purchases | A relying fund is permitted to delay delivery of its prospectus to investors. | The sale of shares to an investor cannot be an initial purchase of shares. A relying fund must deliver its prospectus to investors as soon as practicable, and no later than 45 days after the date originally required. | Not required. | Prompt notice to the SEC staff by email at [email protected]. A relying fund must post notice on its website. | June 30, 2020 |
| Delaying or Changing the Location of Shareholder Meetings | A relying fund may change the date, time or location of its shareholder meeting without mailing additional soliciting materials or amending its proxy materials. | Any changes must also comply with applicable state law requirements. | Not required to rely on the relief (but required to set or change meeting details). | A relying fund must issue a press release and file the announcement as definitive additional soliciting material on EDGAR or, if the meeting is held in connection with a business combination described in a registration statement on Form N-14, the announcement should be filed as a prospectus supplement under 1933 Act Rule 497, and take all reasonable steps necessary to inform other intermediaries in the proxy process of such change. | Such time as delays in meetings are not due to COVID-19. |
| Secured Borrowings from Affiliates | A relying fund may borrow on a secured basis from its investment adviser or other affiliated entities. Provides an exemption from Sections 17(a), 12(d)(3) and 18(f)(1), but not Rule 17d-1. | None. | Board must determine that the loan is in the best interests of the relying fund and will be used to satisfy shareholder redemptions. | Prompt notice to the SEC staff by email at [email protected] stating the fund’s intention to rely on the temporary relief. | June 30, 2020 |
| Modifications to Interfund Lending | A relying fund may make loans through an existing interfund lending (“IFL”) facility in an aggregate amount that does not exceed 25% of its current net assets at the time of the loan notwithstanding any lower limitation in an existing IFL order (typically 15% of current net asset value). A relying fund may borrow or make loans through the facility for any term (up to and including the date this temporary relief is rescinded), notwithstanding any conditions normally limiting the term of such loans. | A relying fund must previously have obtained an IFL order from the SEC or it must agree to adhere to the conditions of one granted to another fund in the 12 months preceding March 23, 2020. The term of any IFL made in reliance on the relief may not extend beyond the expiration of the temporary relief. | Board approval required to extend the maximum term of an interfund loan. | Prompt notice to the SEC staff by email at [email protected] stating the fund’s intention to rely on the temporary relief and, if the fund does not have an IFL order, identifying the existing order it will adhere to. For a fund that had previously been able to rely on an existing IFL order, disclose on its public website that it is relying on an SEC exemptive order that modifies the terms of its existing IFL order. | June 30, 2020 |
| Deviation from Registration Statement Policies | A relying fund may enter into lending or borrowing transactions that deviate from any relevant policy recited in its registration statement without prior shareholder approval. | None. | Required. | Prompt notice to the SEC staff by email at [email protected] stating the fund’s intention to rely on the temporary relief. Must notify shareholders of the deviation by filing a prospectus supplement and includes a statement on the applicable fund’s public website. | June 30, 2020 |
| Permitting Additional Affiliated Transactions to Provide Liquidity | A relying fund’s affiliates that are not registered investment companies may purchase debt securities held by the relying fund notwithstanding the restrictions of Section 17(a). | The debt securities must be sold at fair market value in cash-settled transactions. If the relying fund’s affiliate later sells the purchased security for a higher price than paid to the relying fund, the affiliate must pay the relying fund the difference. | Not required. | Prompt notice to the SEC staff by email at [email protected] and publicly posted on the relying fund’s website stating the name of the affiliate, the securities sold and the quantity and purchase price. | Notice from the SEC staff that the relief is withdrawn. |
| Reducing Cash Distribution Requirements | A relying fund that relies on the safe harbor for distributions under Revenue Procedure 2017-45 may temporarily reduce the aggregate amount of cash included in distributions to shareholders to 10% (down from 20%). | Only applicable to relying funds that qualify as publicly offered RICs. A publicly offered RIC is a RIC the shares of which are continuously offered pursuant to a public offering, regularly traded on an established securities market, or held by fewer than 500 persons at all times during the taxable year. The other conditions for the safe harbor set forth in Revenue Procedure 2017-45 still apply. | Not required to rely on the relief, but required to set dividends and distributions. | Not required. | December 31, 2020 |