SEC Issues IM Guidance Update Regarding Mixed and Shared Funding Orders

The SEC Division of Investment Management issued an IM Guidance Update to address inquires about "mixed and shared funding" orders.

According to the IM Guidance Update, SEC staff members believe that a mutual fund is not required to obtain a mixed and shared funding order prior to offering its shares as an investment option under a variable life and/or annuity contract. Additionally, a fund that has obtained a mixed and shared funding order previously need not comply with the terms and conditions of that order if the exemptions granted by it are not being relied upon by any person.

See: SEC IM Guidance Update.