CCO Resource Center: Closed-End/Interval Fund Share Repurchase Policies and Procedures
Chief Compliance Officer Committee
Closed-End/Interval Fund Share Repurchase Policies and Procedures
In June 2021, I was asked by a member of the CCO Committee to collect the compliance policies and procedures that members have adopted under Section 23 of the Investment Company Act of 1940 relating to their closed-end funds’ repurchase of shares from shareholders. The seven policies and procedures I received in response are compiled in this section of the Resource Center. They are ordered from the shortest (2 pages) to the longest (13 pages). Two of the members who provided me their policies and procedures noted that their firms no longer offer interval funds but, when they did, the policies and procedures they provided to me were used in connection with their tender offers. One of these two firms made such offers quarterly. We have made every effort to redact any identifying or proprietary information from these documents. We apologize in advance if we failed to completely redact such information. Please do not share this document with anyone outside of your member firm. As additional members of the Committee share with us their closed-end fund repurchase policies and procedures, we will add them to this compilation.
The information in ICI’s CCO Resource Center is only intended to be accessed by members of the CCO Committee for their internal use. It is not to be distributed or shared outside of their member organization.