In response to the coronavirus (COVID-19) emergency and potential liquidity issues for registered funds, the SEC has provided temporary relief to allow registered funds to sell assets to, and borrow from, their affiliates in transactions that would otherwise have been prohibited.  This relief includes additional flexibility involving interfund lending and borrowing facilities within multi-fund complexes.

Fund directors will need to consider a variety of factors when weighing these options to address their funds’ current or potential liquidity needs. In this audiocast, the SEC relief and considerations for fund directors were discussed by Nora Jordan, the head of Davis Polk’s Investment Management Group; Greg Rowland, a partner in the group; and Aaron Gilbride, who joined the group as counsel last year after several years in the SEC’s Division of Investment Management.

Related content on Davis Polk Coronavirus Updates includes:

SEC Provides Temporary Additional Flexibility for Registered Funds Affected by the Coronavirus Outbreak to Obtain Short-Term Funding

Client Alert, March 24, 2020

SEC Issues Targeted Regulatory Relief for Advisers and Registered Funds Affected by the Coronavirus Outbreak

Client Alert, March 16, 2020

If you have any questions regarding the matters covered in this publication, please reach out to any of the lawyers listed below or your usual Davis Polk contact.

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