COVID-19: SEC Issues Temporary Conditional Relief to Certain Registered Funds and Insurance Company Separate Accounts with Respect to Short-Term Funding from Affiliates

On March 23, 2020, the US Securities and Exchange Commission issued an order providing exemptions from various provisions of the Investment Company Act of 1940 to provide flexibility to open-end investment companies other than money market funds and insurance company separate accounts registered as unit investment trusts to obtain short-term funding. Each of the exemptions requires conditions to be met. This Legal Update provides further detail.