On March 23, 2020, in response to business disruptions caused by the spread of the coronavirus (“COVID-19”), the Securities and Exchange Commission (“SEC”) issued an exemptive order (the “Order”) under the Investment Company Act of 1940 (“1940 Act”) granting registered investment companies and insurance company separate accounts registered as unit investment trusts (“separate accounts”) regulatory flexibility to obtain short term funding by (1) borrowing money from affiliated persons, (2) engaging in interfund lending outside the scope of existing interfund lending orders, and (3) deviating from fundamental policies. The Order provides this relief until at least June 30, 2020, but the SEC may extend the time period if necessary (the “relief period”).
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