WilmerHale
MONTH-IN-BRIEF (Mar 2025)
SEC Extends Compliance Dates for 2023 Names Rule
By Karen Liu, Reid & Wise LLC
On March 14, 2025, the U.S. Securities and Exchange Commission (the “SEC”) announced a six-month extension (the “Extension”) of the compliance dates for the 2023 amendments to Rule 35d-1 (the “2023 Names Rule”) under the Investment Company Act of 1940 (the “Company Act”). The 2023 Names Rule was adopted by the SEC on September 20, 2023, and effective as of December 11, 2023. The effective date for the Extension is March 20, 2025.
Pursuant to the Extension, the compliance dates for the 2023 Names Rule are as follows depending on the size of funds as of the end of their most recent fiscal year:
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