ComplianceAlert

SEC Provides Clarity for Fund of Funds

The Division of Investment Management (“Division”) of the SEC updated its FAQ for fund of fund arrangements on March 5, 2026. This new FAQ addresses the allowable 10 percent bucket of an acquired fund under Rule 12d1-4(b)(3)(ii) of the Investment Company Act of 1940 (the “Rule”). The Rule contains prohibitions on an acquired fund’s investments with certain exceptions. The Rule exists to prevent duplication of fees and expenses in multi-tiered complex fund structures. Essentially, if…

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ComplianceAlert

CFTC issues No-Action letter to Private Fund CPO/CTAs

The Market Participants Division (“MPD” or “Division”) of the CFTC has issued a crucial no-action letter (“the letter”) to the private fund industry which serves as a follow-on to the December letter (CFTC Letter No. 25-50). This letter (CFTC Letter No. 26-06) provides relief to private funds that are registered with the CFTC as CPOs/CTAs under Regulation 4.7 and delegate to a related Designated CPO. All other components of the letter are the same as…

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