On Jan. 13, 2021, the Division of Investment Management staff (Staff) of the Securities and Exchange Commission (Commission) issued a no-action letter advising that it would not recommend enforcement action to the Commission under Section 17(f) of the Investment Company Act of 1940 (1940 Act), and paragraphs (b)-(f) of Rule 17f-2 thereunder, if certain registered management investment companies or series thereof (Funds), or their directors or officers, if the Funds, acting as self-custodians, maintain certain Loan Interests (as defined below) without strict compliance with paragraphs (b)-(e) of Rule 17f-2.

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Photo of Ryan F. Helmrich Ryan F. Helmrich

Ryan F. Helmrich advises fund complexes, investment managers, broker-dealers, and asset servicing providers on a broad range of investment management regulatory and transactional matters. These include the establishment, representation and reorganization of open- and closed-end funds and exchange-traded funds (ETFs), their advisers and…

Ryan F. Helmrich advises fund complexes, investment managers, broker-dealers, and asset servicing providers on a broad range of investment management regulatory and transactional matters. These include the establishment, representation and reorganization of open- and closed-end funds and exchange-traded funds (ETFs), their advisers and listing markets. He also counsels asset managers on a range of regulatory issues, including registration, interpretive guidance, new product development, regulatory examinations and enforcement actions. He regularly assists clients in conducting internal compliance audits and in developing and maintaining compliance programs. Ryan has broad experience assisting private fund sponsors with formation, advertising, and ongoing regulatory compliance.

Ryan regularly represents financial institutions and other asset service providers regarding the negotiation of servicing agreements and derivatives-trading arrangements, as well as other matters affecting their domestic and global asset-servicing activities (custody, administrative, sub-accounting, and transfer agency).

Photo of Nathan M. Iacovino Nathan M. Iacovino

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and

Nathan M. Iacovino focuses his practice on the investment servicing and investment management industries, advising asset-servicing entities, including custodians, transfer agents, and administrators, in connection with various regulatory and transactional matters. He has supported and developed strategies related to the structuring, negotiation, and implementation of domestic and global custody, fund administration, managed account platforms, collateral management, and related servicing arrangements by and among his custodial, investment servicing and managed account platform provider clients and their respective fund, investor, pension plan, and adviser client base.

Nathan also represents mutual fund complexes, asset managers, investment advisers, institutional investors and financial institutions in developing and maintaining financial products while navigating the regulatory landscape.

Nathan’s clients include a wide range of private funds, registered investment companies, transfer agents, banks, financial institutions, institutional investors and investment advisors.