What Kind Of A Derivatives User Is Your Fund? – Finance and Banking – United States – Mondaq News Alerts

Rule 18f-4 is somewhat
unusual in that it gives management investment companies (including
business development companies but excluding money market funds, “Funds”) alternative means of complying with its
exemption from Sections 18 and 61. A Fund may either:

• Limit the way and extent to which the Fund engages in
  derivatives transactions (a “Limited Derivatives User”),
  or
• Adopt a Derivatives Risk Management Program (a “DRM
  Program”) that, among other requirements, limits the
  Fund’s Value-at-Risk (“VaR”) relative to an index,
  its non-derivatives portfolio or its net assets (a “VaR
  Fund”).

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