COVID-19 UPDATE: SEC to Allow Virtual Board Meetings

March 20, 2020

WHAT HAPPENED?

In response to the international COVID-19 outbreak, the SEC is providing regulatory relief to those who are significantly affected by the pandemic. Due to travel, lodging, and other restrictions imposed by the pandemic, the SEC is allowing for virtual board meetings to take place until June 15, 2020 (extended to Aug. 15, 2020). Important details are as follows:

KEY TAKEAWAYS

• Funds may only rely on exemptive relief if the reasons are due to significant challenges related to the COVID-19 outbreak.
• When casting votes via virtual meeting, it is required that all directors hear one another simultaneously, in real-time.
• At the next in-person meeting, the board of directors must ratify any actions taken by vote via virtual meeting.

WHAT DOES THIS MEAN FOR ME?

If your fund has an upcoming board meeting, we recommend taking advantage of the temporary regulatory relief instated by the SEC. In the unprecedented circumstances created by COVID-19, regulatory relief provisions are subject to change. FilePoint will keep you up to date with the most important information during this unique time.