COVID-19 Coronavirus: Financial Services

The outbreak of the COVID-19 coronavirus is causing business disruption on an unprecedented scale. After more than a decade of sustained economic growth, market volatility and central bank intervention has returned. Dechert's private funds team presents this report of general considerations for all fund and alternative asset managers to help them navigate this complex and fast-changing situation.

Read our guidance: Facing a Global Challenge: Key Considerations for Fund Managers (Global) - March 26, 2020

On March 23, 2020, the SEC issued an order providing relief to registered open-end funds and insurance company separate accounts registered as unit investment trusts. The SEC order follows two previous orders which provided relief to funds and investment advisers whose operations may be affected by the COVID-19 coronavirus outbreak. The relief will remain in effect through at least June 30, 2020.

Read our guidance: SEC Takes Further Action to Assist Funds in Light of COVID-19 Coronavirus Pandemic: Provides Flexibility for Funds and Insurance Company Separate Accounts to Obtain Short-Term Funding (U.S.) - March 25, 2020

The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators (CPOs) on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue certain reports that would otherwise be due in the near term.

Read our guidance: CFTC and NFA Issue Relief for Registered CPOs and CTAs in Response to Disruptions Caused by COVID-19 Coronavirus Pandemic (U.S.) - March 23, 2020

Our lawyers cover how the exceptions in executive orders that otherwise restrict business activities of business and residents in the relevant states may affect the ability of asset managers and certain of their personnel to continue certain activities in their offices. 

Read our guidance: Executive Orders Restricting Business Activities – Implications for Asset Managers (U.S.) - March 22, 2020

Public markets have seen severe dislocation with all major stock markets shedding 10 to 30 percent in the past few weeks due primarily to fears about COVID-19 coronavirus and the slump in oil prices.

Read our guidance: Market Disruption: Fund Restructuring Considerations for Private Equity (Global) – March 19, 2020

As financial markets react to daily, dramatic news headlines concerning the coronavirus pandemic, an oil market price war, extraordinary government responses and the economic and financial fallout, funds and their liquidity program administrators may want to keep in mind a few key points under the Securities and Exchange Commission’s Liquidity Risk Management Rule.

Read our guidance: Liquidity Rule Reminders in Light of Recent Market Turmoil (U.S.) – March 17, 2020

On March 13, 2020, the SEC issued two orders providing relief related to filings and in-person board meetings to registered funds and investment advisers whose operations may be affected by the COVID-19 coronavirus outbreak. In each order, the SEC acknowledged that coronavirus-related disruptions may pose challenges to satisfying certain requirements under the Investment Company Act of 1940 as well as the Investment Advisers Act of 1940.

In light of these challenges, the SEC provided certain temporary, conditional relief for registered investment companies, unit investment trusts and business development companies, as well as for registered investment advisers (RIAs) and exempt reporting advisers (ERAs). Additionally, the SEC included a statement regarding SEC enforcement action related to certain disclosure delivery obligations.

Read our guidance: SEC Takes Targeted Action to Assist Funds and Advisers in Light of COVID-19 Coronavirus Pandemic (U.S.) – March 16, 2020