Special Opportunities Fund asks SEC staff to review three proposed anti-takeover bylaws
The fund sent a December 2, 2019 letter asking the SEC Division of Investment Management whether proposed bylaws on share ownership limits, majority voting for directors and continuing directors would violate the Investment Company Act of 1940. The Board has not adopted any of the proposed bylaws and says it will consider the staff's determination before acting, so no change to shareholder rights has taken effect.
- Letter dated December 2, 2019 to the SEC Division of Investment Management, filed under Regulation FD on December 3, 2019
- Three proposed bylaws: a share ownership limitation, a majority voting requirement for director election, and a continuing director bylaw
- The Board has taken no action to adopt the proposed bylaws and will await the staff's determination