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SEC Fund of Funds Rule
The Securities and Exchange Commission (SEC) adopted new rule 12d1-4 under the Investment Company Act of 1940, as amended (1940 Act), designed to streamline the regulatory framework applicable to funds that invest in other funds (funds of funds). The new rule significantly reorders the current web of regulation applicable to fund of funds arrangements by subjecting most funds of funds to Rule 12d1-4. Accordingly, the SEC will rescind Rule 12d1-2 under the 1940 Act and certain of the currently effective individual exemptive orders for fund of funds arrangements.
Rule 12d1-4 will be effective 60 days after publication in the Federal Register. The rescission of Rule 12d1-2 and the existing exemptive orders will be effective one year after the effective date of Rule 12d1-4.
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Thought Leadership
On 23 April 2025, the European Commission has issued its first ever fines under the Digital Markets Act (DMA): a €500 million fine on Apple for violation of the DMA’s prohibition of anti-steering provisions for app stores, and a €200 million for Meta’s “pay or consent” model that was found to be a violation of the DMA’s requirement of seeking user consent for gatekeepers before combining user data between their different services.
On 30 June 2025, both the US Department of Energy and the Federal Energy Regulatory Commission announced revisions to their respective National Environmental Policy Act procedures to speed up the permitting process for energy infrastructure.
On 3 July 2025, the House passed the Senate’s version of H.R. 1, the budget reconciliation bill formerly known as the “One Big Beautiful Bill Act”.
In May 2025, Washington Governor Bob Ferguson signed into law several bills that will impact both individual and business taxpayers.