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Compliance with Rule 18f-4 by a Fund-of-Funds

By Stephen A. Keen & Perkins Coie on December 9, 2021
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The release adopting Rule 18f-4 (the “Adopting Release”) devotes an entire section to discussing how “a fund that invests in other registered investment companies (‘underlying funds’)” should comply with the value-at-risk (“VaR”) requirements of the rule. This post considers three circumstances in which a fund investing in underlying funds:

  1. Does not invest in any derivatives transactions (a “Non-User Fund-of-Funds”);
  2. Allows its derivatives exposure to exceed 10% of its net assets (a “VaR Fund-of-Funds”) ; and
  3. Limits its derivatives exposure to 10% of its net assets (a “Limited Derivatives User Fund-of-Funds”).

We use the term “Fund-of-Funds” for convenience, meaning to include funds that hold both direct investments and underlying funds in compliance with Rule 12d1-4 or other exemptions.

Continue to the full blog post at The Asset Management ADVocate.

  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Derivatives & Repo Report
  • Organization:
    Perkins Coie LLP
  • Article: View Original Source

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