Interval Funds


Stradley Ronon’s investment management group provides legal advice to a variety of closed-end funds, including those structured as “interval funds” that operate pursuant to Rule 23c-3 under the Investment Company Act of 1940 and “tender offer funds” that do not rely on the rule. Our attorneys have extensive experience with regard to the creation and operation of these types of funds, including with respect to initial structuring decisions, formation and registration, corporate actions such as reorganizations, drafting regulatory filings for periodic tender offers, obtaining exemptive relief for multi-class and distribution fee structures, advising on ongoing compliance and regulatory issues and counseling the boards of trustees that oversee these types of funds.

Experience with Alternative Assets
Our attorneys are well-versed in helping funds and boards address the complex liquidity, valuation and custody issues related to the alternative assets in which many interval funds and tender offer funds invest, including energy investments, real estate securities and REITs, frontier markets securities, late-stage private companies, private credit (directly originated loans and senior securities), syndicated debt, distressed debt, marketplace loan investments, and alternative/harder to access credit investments (including public and private below-investment-grade and nonrated debt, as well as collateralized/structured/asset-backed obligations).

Uniquely Positioned to Add Value
By bridging both the private fund and registered fund worlds, Stradley Ronon is uniquely positioned to assist asset managers who are interested in implementing their alternative strategies in a registered fund vehicle in order to gain access to the retail marketplace. Our significant experience with derivative instruments, including their trading and documentation, has allowed us to assess early in the process any “showstopper” issues, advise on complicated compliance questions and assist management in educating fund boards on these new products. Many of our clients have liquid alternatives funds or funds that employ such strategies.

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