SEC Publishes Investment Management Guidance on Electronic Delivery of Distributions to Shareholders

The SEC Division of Investment Management published guidance regarding whether management investment companies (funds) registered under the Investment Company Act that make distributions to their shareholders – where the distribution is derived from any source other than the fund's net income – may electronically deliver the required "written statement" describing the sources of those distributions.

According to the guidance, the SEC staff determined that electronic delivery of a Rule 19a-1 Notice ("Written Statement to Accompany Dividend Payments by Management Companies") satisfies the purposes and policies underlying Rule 19a-1, despite the rule's reference to "a separate paper."

See: IM Guidance Update.