Investment Services Regulatory Update - January 2018

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New Rules, Proposed Rules, Guidance and Alerts -

SEC STAFF GUIDANCE AND ALERTS -

Division of Investment Management Staff Issues Liquidity Risk Management Program FAQs -

On January 10, 2018, the staff of the SEC’s Division of Investment Management issued guidance in the form of frequently asked questions (FAQs) relating to the liquidity risk management (LRM) program requirements of Rule 22e-4, which was adopted in October 2016. The FAQs generally address two categories of questions: (i) the delegation of LRM program administrative duties to sub-advisers and (ii) the definition and applicability of Rule 22e-4 to “In-Kind ETFs.” The following is a summary of the issues addressed in the FAQs.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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