In late December, the SEC proposed changes it said would “streamline and enhance the regulatory framework applicable to funds that invest in other funds.” The proposal would rescind Rule 12d1-2 and most funds-of-funds-related exemptive orders and instead provide a new framework for funds of funds under a new Rule 12d1-4. Our client memo examines the scope of the proposed rule and what the changes would mean in areas including voting, redemptions and fees.


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