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Form 40-6B Filings

SEC Form 40-6B is an application filed by an Employees’ Securities Company (ESC) to seek an exemption from certain provisions of the Investment Company Act of 1940.

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ID Form Filer Name Filing Agent Date Actions
2188258540-6BRobinhood Markets, Inc.Davis Polk & Wardwell Llp 01/fa07/16/2026
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2299874040-6BRobinhood Markets, Inc. Self 07/16/2026
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2286314440-6BMarshall Wace, Llp Self 05/11/2026
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What Is SEC Form 40-6B?

SEC Form 40-6B is filed under Section 6(b) of the Investment Company Act of 1940. It is used by employee securities companies investment vehicles (like limited partnerships) formed by an employer for the benefit of its employees, to apply for an order exempting them from various restrictive provisions of the Act.4

The purpose of the form is to allow these internal investment funds to operate with more flexibility than a standard mutual fund, provided that the SEC finds the exemption consistent with the protection of the employee-investors.

Key elements typically found in SEC Form 40-6B include:

  • Identification of the employer and the specific investment fund (the ESC)
  • Detailed description of the investment program and eligibility for employees
  • Specific sections of the 1940 Act from which the exemption is being sought
  • Legal arguments and factual background supporting why the exemption is appropriate
  • Certification that the fund\'s operation is consistent with the protection of investors

SEC Form 40-6B Filing Deadlines

This is a transaction-based application rather than a periodic filing.

Trigger Event When Form 40-6B Is Filed Purpose
Formation of a new ESC Before commencing operations Request exemptive relief from the SEC
Material change to fund terms As an amendment (40-6B/A) Update the terms of the existing order
Request for additional relief Upon determination of need Expand the scope of the exemption

 Key Things to Know About Form 40-6B Filing Rules

  • Investment Company Act Focused: This is not a 34 Act or 33 Act registration; it is an exemptive application under the 1940 Act.
  • Applies to Internal Funds: Used primarily by private equity firms, venture capital firms, and large corporations for employee-only investment vehicles.
  • Review Process: Unlike a standard notice filing, this application undergoes a formal review by the SEC\\\'s Division of Investment Management.
  • Public Notice: After the application is filed, the SEC typically issues a notice to the public, allowing for a comment period before granting the order.

To track investment company fidelity bond filings and insurance coverage activity, our platform helps you monitor filings such as Form 40-6B, Form 40-17G, and Form 40-17GCS, keeping you informed about bonding requirements and compliance safeguards for funds

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