SEC Issues Notice on Exemption Application for DLA Piper Employee Funds
SEC notice seeks to exempt DLA Piper employee investment funds from most 1940 Investment Company Act provisions, unless a hearing is requested by Nov. 2, 2026.
On October 7, 2026, the SEC issued a notice (Investment Company Act Release No. 36356; File No. 813-00421) of an application for an order under sections 6(b) and 6(e) of the Investment Company Act of 1940. The applicants, DPP Investors 2025 LP and DLA Piper LLP (US), seek an exemption from all provisions of the Act except sections 9, 17, 30, and 36 through 53, and the related rules.
The exemption would apply to limited liability companies, partnerships, trusts, corporations or other entities formed for the benefit of eligible DLA Piper employees and its affiliates. Each such entity would be classified as an "employees' securities company" within the meaning of section 2(a)(13) of the Act. The applicants also request a limited exemption concerning sections 17(a), (d), (f), (g), (j); sections 30(a), (b), (e), (h); the Rules and Regulations; and rule 38a-1.
The SEC states that an order granting the relief will be issued unless the Commission orders a hearing. Interested persons may request a hearing by emailing the SEC's Secretary and serving the applicants, with requests due by 5:30 p.m., Eastern time, on November 2, 2026. Requests must include the file number and be accompanied by proof of service.
The original application was filed on February 28, 2025 and subsequently amended on February 26, 2026 and September 30, 2026. The second amended application dated September 30, 2026 is available on the SEC's website or through the EDGAR system using the file number above. For further information, contact Stephan N. Packs, Senior Counsel, or Matthew Cook, Branch Chief, at (202) 551-6720.
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