How The SEC Eased In-Person Director Voting Rules

By Stuart Coleman, Janna Manes, Nicole Runyan, Robert Plaze and Will Tuttle (March 21, 2019, 2:53 PM EDT) -- On Feb. 28, 2019, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission issued a no-action letter[1] permitting the board of directors of a registered fund or business development company[2] to meet and take certain actions by telephone, video conference or other similar means in circumstances where directors are unable to meet in person due to unforeseen or emergency situations, or previously met in person and discussed all material aspects of the matter, but did not vote on the matter during the in-person meeting....

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