Statute
Rule 18f-4
37 published works
Derivatives & Repo Report
Rule 18f-4 Wrap-Up
By Stephen A. Keen, Perkins Coie
This post will bring to a close, for now, our survey of the requirements of new Rule 18f-4, which investment companies must comply with by August 19, 2022. This post considers whether a…
Derivatives & Repo Report
Compliance with Rule 18f-4 by a Fund-of-Funds
By Stephen A. Keen, Perkins Coie
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…
Derivatives & Repo Report
Compliance with Rule 18f-4 by a Sub-Advised Fund
By Stephen A. Keen, Perkins Coie
As with Fund-of-Funds, the release adopting Rule 18f-4 (the “Adopting Release”) devotes a section to sub-advised funds. We again consider three types of funds: VaR Funds in which a sub-adviser manages their…
Derivatives & Repo Report
Assessing the Limited Derivatives User Requirements of Rule 18f-4—Notional Amounts
By Stephen A. Keen, Perkins Coie
This post continues our assessment of whether the Limited Derivatives User requirements of Rule 18f-4(c)(4) effectively and efficiently accomplish the SEC’s aim of providing “an objective standard to identify funds that…
Derivatives & Repo Report
Assessing the Limited Derivatives User Requirements of Rule 18f-4—Costs
By Stephen A. Keen, Perkins Coie
Our last series of posts on Rule 18f-4 have struggled to understand how its Limited Derivatives User requirements are supposed to work. We have done the best we could to explain the process for calculating…
Derivatives & Repo Report
Compliance Checklist for Limited Derivatives Users
By Stephen A. Keen, Perkins Coie
As has been our practice in this series on new Rule 18f-4, we end our survey of its Limited Derivatives User requirements with a compliance checklist. This checklist reiterates much of our…
Derivatives & Repo Report
Hedging Derivatives under Rule 18f-4: Not an “All or None” Exclusion
By Stephen A. Keen, Perkins Coie
This post will address another ambiguity in the “10% buffer” Rule 18f-4 provides for excluding the notional amount of derivative transactions that hedge currency or interest rate risks (“Hedging Derivatives”)…
Derivatives & Repo Report
Rule 18f-4: One 10% Buffer or Many?
By Stephen A. Keen, Perkins Coie
This post continues our examination of the “10% buffer” for Hedging Derivatives, which refers to the amount by which the notional amounts of Hedging Derivatives can exceed the value, par or…
Derivatives & Repo Report
Rule 18f-4: The 10% Buffer and Changes in Hedged Investments
By Perkins Coie
By Stephen A. Keen and Andrew P. Cross This post continues our examination of the “10% buffer” for Hedging Derivatives, which refers to the amount by which the notional amounts of…
Derivatives & Repo Report
Limited Derivatives Users—Applying the Interest Rate Hedging Exclusion
By Perkins Coie
By Stephen A. Keen and Andrew P. Cross Our last post examined examples of currency hedges that we believe Rule 18f‑4(c)(4)(i)(B) should allow a fund seeking to comply with the Limited Derivatives…