SEC Permits Certain “Master-Feeder” Arrangements

Although obstacles remain

BRENDAN C. FOX, BRENDEN P. CARROLL, COLMAN O’LOGHLEN, PRIYA H. PATEL, DECHERT LLP

The Staff of the US Securities and Exchange Commission (SEC) on March 8, 2017 issued a no-action letter (Staff Letter) in response to a request from Dechert LLP for assurance under Section 12(d)(1) of the Investment Company Act of 1940 (1940 Act).1 The Staff Letter provides no-action assurance to global investment managers and sponsors seeking to offer investment products across non-US jurisdictions using a “master-feeder” arrangement that...

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