Addressing Questions Under the Amended Registered Fund Names Rule (Volume 58, Number 2—January 22, 2025)
Author: Philip T. Hinkle.; Corey F. Rose.; Dale C. Beggs.; Austin G. McComb.
Source: Volume 58, Number 02, January 15 2025 , pp.9-23(15)
Abstract:
Recent amendments to Rule 35d-1 under the Investment Company Act of 1940 — commonly known as the “Names Rule” — broaden the scope of terms in fund names subject to the rule, impose enhanced disclosure and compliance requirements on funds related to their names, and describe how to treat derivatives instruments and short positions under the rule. This article discusses certain interpretive questions fund managers face in implementing these amendments ahead of the December 2025 compliance date.Keywords: Rule 35d-1 (“Names Rule”); “Materially Deceptive or Misleading” Definition; 80% Investment Policy; Tax-Exempt Fund Requirements; Derivatives-Related Aspects
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