Published on Mar 6th, 2020 |

As a result of the current and potential effects of Coronavirus (“COVID-19”), the staff at the Division of Investment Management is hereby extending the no-action position expressed in the Independent Directors Council letter with respect to unforeseen or emergency circumstances to cover all approvals and renewals (including material changes) of contracts, plans or arrangements under section 15(c) or rules 12b-1 or 15a-4(b)(2).

This position applies to board meetings held between the date of this update and June 15, 2020.  The Division staff may extend the time period for this no-action position as circumstances warrant, with any additional conditions deemed appropriate.

The Division encourages investment advisers and funds to contact the Division staff with any concerns they have related to the staff letter or to current or potential effects of COVID-19 on their operations, including any need for relief or guidance, at 202-551-6825 or email at

If you’d like to read the full release from the SEC, see here.