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RBC BlueBay Seeks SEC Relief to Link Interval Fund to Private Credit Strategies

By Mari Nicholson

RBC BlueBay Seeks SEC Relief to Link Interval Fund to Private Credit Strategies

RBC BlueBay Asset Management is asking the U.S. Securities and Exchange Commission for permission to let a retail-accessible interval fund co-invest alongside its full family of private credit vehicles, an amended application filed Aug. 25 shows.

The filing seeks an order under Sections 17(d) and 57(i) of the Investment Company Act of 1940 and Rule 17d-1 permitting co-investment transactions among a group of RBC BlueBay-managed funds spanning a registered interval fund, an open-end mutual fund trust, and a roster of private, offshore credit strategies. The SEC has not ruled on the request. The document is Amendment No. 1, filed nearly 10 months after the original application.

The interval fund at the center of the application is BlueBay Destra International Event-Driven Credit Fund, a closed-end fund originally registered as Destra International & Event-Driven Credit Fund. The fund adopted the BlueBay name in 2021, after RBC Global Asset Management (UK) Limited became its investment sub-adviser. It continues to operate as an interval fund, offering quarterly repurchase opportunities.

The order, if granted, would let that fund, along with RBC BlueBay Enhanced Income Fund and several series of RBC Funds Trust – an open-end mutual fund trust formerly known as Tamarack Funds Trust – co-invest alongside a set of BlueBay’s private and offshore vehicles named in the application: the BlueBay Event Driven Credit Fund and its master-fund and limited-partnership counterparts, BlueBay Developed Markets Special Situations Fund I and a related investment vehicle, and BlueBay Global Securitized Credit Opportunities Fund and its own master-fund and limited-partnership counterparts, structured in the Cayman Islands and Luxembourg.

If the SEC grants the order, it would formally connect a retail-accessible, ’40 Act-registered vehicle to RBC BlueBay’s institutional credit book – event-driven credit, securitized credit, and special-situations strategies that otherwise sit outside the reach of interval-fund investors. Sponsors have increasingly sought to give registered vehicles more direct access to the private strategies that have driven asset growth across the credit-fund industry.

RBC BlueBay Asset Management traces back to BlueBay Asset Management, a London-based fixed-income specialist founded in 2001 to focus on European corporate and global emerging-market debt. Royal Bank of Canada acquired BlueBay in a deal that closed in December 2010, and the firm operated as a standalone brand within RBC Global Asset Management for more than a decade before BlueBay formally merged with RBC Global Asset Management (UK) in 2022 and adopted the RBC BlueBay name. The combined firm runs fixed-income and equity strategies out of investment teams in the United Kingdom, the United States, and Hong Kong, serving institutional and retail clients globally.

Sections 17(d) and 57(a)(4) of the ’40 Act generally bar a registered fund from joint transactions with affiliated entities absent SEC exemptive relief, a restriction meant to prevent a fund’s adviser from favoring one client’s portfolio in a shared deal over another’s. Applicants seeking this type of order typically argue the restriction otherwise blocks their registered funds from attractive co-investment opportunities alongside affiliated strategies, an argument RBC BlueBay’s filing makes as well. The filing does not indicate when the SEC might act on the amended application.

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