Master Fund May Deduct Feeder Fund Assets when Calculating Registration Fees
The staff of the SEC’s Division of Investment Management granted no-action relief to reduce registration fees paid by a master fund in an affiliated master-feeder structure. The relief allows a 1933 Act registered master fund to exclude assets invested through affiliated 1933-Act feeder funds for purposes of calculating the registration fees payable pursuant to Section 6(b) of the 1933 Act and Section 24(f) of the 1940 Act. The staff accepted the argument that the exclusion would avoid double-counting of the same assets for purposes of paying the registration fee. The staff indicated that the feeder funds would invest 95% of their assets in the master fund.