Global/International Funds Must Invest 40% of Assets in at Least 3 Countries

In a memo to members, the Investment Company Institute has indicated that it has received guidance from the SEC disclosure staff about funds using the terms “global” or “international” in their names. The ICI says that the SEC staff may require such a fund to invest at least 40% of its assets outside the U.S. and in at least three different countries. In addition, the fund would be required to describe how its investments are tied economically to these countries. The ICI reports that the staff indicated that this may not be the only way to describe international or global investing. The names rule (35d-1) requires a fund to invest at least 80% of its assets in the type of securities indicated by the name, although the terms “international” and “global” are not included.