On October 28, 2020, the Securities and Exchange Commission
("SEC") finalized Rule 18f-4 under the Investment Company
Act; 1 a new rule designed to provide an updated and
comprehensive framework for the use of derivatives by mutual funds,
exchange-traded funds (ETFs), registered closed-end funds, and
business development companies (BDCs) (each, a
"fund").2 Under Rule 18f-4, a fund may
enter into derivatives transactions, notwithstanding the
restrictions on the issuance of senior securities under the
Investment Company Act, as long as the fund complies with the
conditions set forth in the rule. Additional information regarding
Rule 18f-4 and its conditions can be found in our recently
published Legal Alert.