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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On February 19, 2020, the Securities and Exchange Commission (SEC) granted exemptive relief to the Blackstone Alternative Investment Fund (Fund) and its adviser, Blackstone Alternative Investment Advisors LLC (Adviser), which, subject to certain conditions, allows the Fund’s board of trustees to approve new sub-advisory agreements and make material amendments to existing sub-advisory agreements without complying with the in-person meeting requirement of Section 15(c) of the Investment Company Act of 1940 (1940 Act).

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The Adviser’s multi-manager structure provides investors exposure to multiple strategies in one fund. Each sub-adviser’s contract must be entered into, materially amended and renewed in accordance with Section 15(c). In requesting relief, the Fund and Adviser noted that market conditions or investment opportunities may necessitate a change in sub-advisers in between quarterly board of trustees meetings.

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The SEC granted the relief request, subject to the following conditions:

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In granting this exemptive relief, the SEC demonstrated its willingness to rely upon technology in lieu of the 1940 Act’s outdated requirements, noting that the current in-person obligation creates artificial impediments that hinder a board of trustees’ ability to respond to market conditions without the unnecessary burdens of an in-person meeting.

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Andrew J. Davalla 614.469.3353 <a href="mailto:Andrew.Davalla@ThompsonHine.com">Andrew.Davalla@ThompsonHine.com</a>

Brian Doyle-Wenger 614.469.3294 <a href="mailto:Brian.Doyle-Wenger@ThompsonHine.com">Brian.Doyle-Wenger@ThompsonHine.com</a>

This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel. This document may be considered attorney advertising in some jurisdictions.

https://admin.thompsonhine.com/wp-content/uploads/2022/05/Investment_Management_Update_-_SEC_Grants_Relief_Overriding_In-Person_Meeting_Requirement.pdf

SEC Grants Relief Overriding In-Person Meeting Requirement

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