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Supreme Court Narrows Activist Toolkit Against Closed-End Funds
On June 11, 2026, the Supreme Court handed closed-end funds a significant victory over activist investor Saba Capital. In <z>FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd.</z>, No. 24-345, 608 U.S. ___ (June 11, 2026), the Court held that Section 47(b) of the Investment Company Act (“ICA”) does not create an implied private right of action to seek rescission of contracts that allegedly violate the Act.
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