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ARTICLE · 11 NOVEMBER 2018

SEC Permits Fund Board Reliance On CCOs

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Funds permitted to rely on the no-action relief include both registered investment companies and business development companies.

United StatesCorporate/Commercial Law
Brian D. Hirshberg
Brian D. Hirshberg
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On October 12, 2018, the Securities and Exchange Commission's Division of Investment Management issued a no-action letter permitting a fund's board of directors ("Board") to rely upon quarterly compliance certifications from the fund's chief compliance officer ("CCO") that address the fund's compliance when the fund is engaging in certain affiliate transactions under the Investment Company Act of 1940, as amended (the "1940 Act"), instead of requiring the Board to itself determine compliance.  Funds permitted to rely on the no-action relief include both registered investment companies and business development companies.  The no-action relief is limited to the CCO making a determination of whether a particular transaction that is exempt pursuant to Rule 10f-3 (exempts certain securities purchases by an affiliated underwriting syndicate), Rule 17a-7 (exempts certain cross trade transactions between affiliated entities) or Rule 17e-1 (exempts certain affiliated

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