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On February 6, the staff of the SEC’s Division of Investment Management issued a no-action letter with respect to Rule 3c-5 of the Investment Company Act of 1940 that represents a substantial improvement over the existing guidance regarding the definition of "knowledgeable employees" thereunder.
On February 6, the staff of the SEC's Division of Investment
Management issued a no-action letter with respect to Rule 3c-5 of
the Investment Company Act of 1940 (the Company Act) that
represents a substantial improvement over the existing guidance
regarding the definition of "knowledgeable employees"
thereunder, i.e., persons who are not required to be
"qualified purchasers" under Section 3(c)(7) of the
Company Act, or to be counted for purposes of the 100 beneficial
owner limit under Section 3(c)(1) of the Company Act. Response.
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