The SEC’S Proposed Changes to Its Names Rule
Author: Corey F. Rose.; Matthew E. Barsamian.; Austin G. McComb.; Nadeea R. Zakaria.
Source: Volume 55, Number 22, December 15 2022 , pp.257-264(8)
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Abstract:
In this article, the authors discuss the SEC’s proposed changes to its names rule (Rule 35d-1) in detail. They begin with the statutory and regulatory background. They then turn to the proposed rule changes, observing at the outset that the proposal would dramatically expand the universe of terms that would be covered by the rule. They then discuss other topics related to a fund’s announced 80% investment policy. They conclude with a critique of the proposal’s interpretive uncertainty and compliance burden.Keywords: Inv. Co. Act Rel. No. IC-34593 (2022); Rule 35d-1; Use of Materially Deceptive or Misleading Names; 80% Investment Policies
Affiliations:
1: Dechert LLP; 2: Dechert; 3: Dechert; 4: Dechert.