SEC Provides Clarity for Fund of Funds
FrontLine Compliance
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…