In this final post in our series, we consider some of the competing views around the regulation of ESG investing and offer considerations for registered fund boards in today’s unsteady ESG environment.
fund board
VaR Funds vs. Limited Derivatives Users—Programs vs. Procedures
By Perkins Coie on
Posted in Compliance, Registered Investment Companies
Our last post explained the two basic alternatives for managing derivatives risks under new Rule 18f-4 by qualifying either as a Limited Derivatives User or a VaR Fund. This post outlines the essential differences between VaR Funds and Limited Derivatives Users, primarily that the former must adopt a derivatives risk management program (a “DRM Program”) while the latter need only have policies and procedures.