Statement Summary
The Securities and Exchange Commission (SEC) has issued a notice regarding an application from Virtus Global Credit Opportunities Fund and Virtus Investment Advisers, LLC, seeking an exemption under the Investment Company Act of 1940. The application requests permission for certain registered closed-end investment companies to issue multiple classes of shares while imposing asset-based distribution and service fees, along with early withdrawal charges. The application, filed on March 7, 2025, has been amended several times, with a deadline for public hearing requests set for May 27, 2025. Interested parties can contact the SEC or the Applicants for further details. For more information on the application and related documentation, it can be accessed through the SEC’s EDGAR system.
Original Statement
SECURITIES AND EXCHANGE COMMISSION
Investment Company Act Release No. 35565; 812-15717
Virtus Global Credit Opportunities Fund and Virtus Investment Advisers, LLC
May 2, 2025
AGENCY: Securities and Exchange Commission (“Commission” or “SEC”).
ACTION: Notice.Notice of an application under section 6(c) of the Investment Company Act of 1940 (the “Act”) for an exemption from sections 18(a)(2), 18(c) and 18(i) of the Act, under sections 6(c) and 23(c) of the Act for an exemption from rule 23c-3 under the Act, and for an order pursuant to section 17(d) of the Act and rule 17d-1 under the Act.
Summary of Application: Applicants request an order to permit certain registered closed-end investment companies to issue multiple classes of shares and to impose asset-based distribution and/or service fees and early withdrawal charges.
Applicants: Virtus Global Credit Opportunities Fund and Virtus Investment Advisers, LLC
Filing Dates: The application was filed on March 7, 2025, and amended on April 14, 2025 and April 30, 2025.Hearing or Notification of Hearing: An order granting the requested relief will be issued unless the Commission orders a hearing. Interested persons may request a hearing on any application by e-mailing the SEC’s Secretary at Secretarys-Office and serving the Applicants with a copy of the request by e-mail, if an e-mail address is listed for the relevant Applicant below, or personally or by mail, if a physical address is listed for the relevant Applicant below. Hearing requests should be received by the Commission by 5:30 p.m. on May 27, 2025, and should be accompanied by proof of service on the Applicants, in the form of an affidavit, or, for lawyers, a certificate of service. Pursuant to rule 0-5 under the Act, hearing requests should state the nature of the writer’s interest, any facts bearing upon the desirability of a hearing on the matter, the reason for the request, and the issues contested. Persons who wish to be notified of a hearing may request notification by emailing the Commission’s Secretary.
ADDRESSES: The Commission: Secretarys-Office
Applicants: Kathryn L. Santoro, Esq., Virtus Global Credit Opportunities Fund, kate.santoro with copies to Mark Perlow, Esq., Dechert LLP, Mark.Perlow and Stephanie Capistron, Esq., Dechert LLP, Stephanie.CapistronFOR FURTHER INFORMATION CONTACT: Trace W. Rakestraw, Senior Special Counsel, at (202) 551-6825 (Division of Investment Management, Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: For Applicants’ representations, legal analysis, and conditions, please refer to Applicants’ application, dated April 30, 2025, which may be obtained via the Commission’s website by searching for the file number at the top of this document, or for an Applicant using the Company name search field on the SEC’s EDGAR system. The SEC’s EDGAR system may be searched at You may also call the SEC’s Office of Investor Education and Advocacy at (202) 551-8090.
For the Commission, by the Division of Investment Management, under delegated authority.
Sherry R. Haywood,
Assistant Secretary.
