Simpson Thacher Lawyers Author Article on Updated SEC Framework Governing the Use of Derivatives by Regulated Funds
03.17.21
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Partners David Blass, Ryan Brizek and Rajib Chanda, and Associates Debbie Sutter and Andy Madore authored an article titled, “Simpson Thacher Discusses SEC Framework for Use of Derivatives by Regulated Funds,” which was published by Columbia Law School’s Blue Sky Blog. The article analyzed the SEC’s recently adopted Rule 18f-4 under the 1940 Act which overhauls the regulatory framework for the use of derivatives and similar transactions by regulated funds, including registered closed-end funds, BDCs and registered open-end funds (including mutual funds and ETFs but excluding money market funds). It further highlighted the key attributes of the rule and related requirements, as well as changes suggested during the comment period and the result in the final rule.
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