Investment Services Regulatory Update - March 2018

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New Rules, Proposed Rules, Guidance and Alerts -

PROPOSED RULES -

SEC Proposes Changes to Fund Liquidity Disclosure Requirements -

On March 14, 2018, the SEC issued proposed amendments to the disclosure requirements concerning certain fund liquidity information. Fund liquidity reporting relates to new Rule 22e-4 under the Investment Company Act of 1940, as amended (the Liquidity Rule), which requires each fund to adopt and implement a written liquidity risk management (LRM) program reasonably designed to assess and manage the fund’s liquidity risk. A fund’s LRM program must include certain components, including, among other things, that a fund classify the liquidity of each portfolio investment into one of four categories (or “buckets”): highly liquid investments, moderately liquid investments, less liquid investments and illiquid investments.

Please see full publication below for more information.

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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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