SEC Amends Investment Company Liquidity Rule Disclosure Requirements

by Dechert LLP

Dechert LLP

The U.S. Securities and Exchange Commission has adopted amendments to certain disclosure requirements of open-end investment companies – including exchange-traded funds, but excluding money market funds – (collectively, funds), relating to liquidity risk management programs.1 The amendments:

  • Replace the requirement that funds publicly disclose their aggregate liquidity classification information on Form N-PORT2 with a new requirement under Form N-1A that funds discuss the operation and effectiveness of their liquidity risk management program in their annual or semi-annual report to shareholders.

  • Permit funds to classify single investments into multiple liquidity classification “buckets” in three specified circumstances.

  • Adopt a new requirement that funds disclose their cash holdings and certain cash equivalents on Form N-PORT.

In addition, partly in response to comments from industry participants as to the benefits of the liquidity classification requirements set forth in Rule 22e-4 under the Investment Company Act of 1940 (Liquidity Rule),3 the adopting release appears to invite industry participants to seek exemptive relief if they “believe they would have to maintain dual liquidity classification programs as part of their liquidity risk management.” The adopting release also notes that the SEC and its staff will continue to evaluate the implementation of the Liquidity Rule, signaling the possibility of further enhancements to that rule in the future.


In 2016, the SEC adopted the Liquidity Rule to require funds to establish liquidity risk management programs. The Liquidity Rule prescribed certain elements for these programs, including that a fund classify each individual portfolio holding into one of the following four liquidity classifications (or “liquidity buckets”): (i) highly liquid investment; (ii) moderately liquid investment; (iii) less liquid investment; or (iv) illiquid investment. As originally adopted, Form N-PORT also included a requirement that funds disclose, on a monthly basis, the aggregate percentage of their portfolio holdings that fall into each liquidity bucket. The aggregate liquidity classification information reported to the SEC on the Form N-PORT filed for the third month of a fund’s fiscal quarter would have been made public after a 60-day lag period. As initially adopted, Form N-PORT also did not require funds to report their cash holdings or cash equivalents that are not portfolio investments.

Replacing Aggregate Liquidity Classifications with New Narrative Discussion

The amendments remove the requirement that funds publicly report their aggregate liquidity classification information on Form N-PORT. Instead, the amendments add a new sub-item to Form N-1A that requires funds to include in their annual or semi-annual report a brief discussion of the “operation and effectiveness of the fund’s liquidity risk management program over the past year.” In a departure from the proposing release and in response to industry commenters, the amendments add the narrative discussion to a new subsection of the shareholder report rather than folding it into management’s discussion of fund performance.4

A fund must provide the narrative discussion in the shareholder report that covers the most recent fiscal half-year in which the fund’s board of directors reviewed the fund’s liquidity risk management program as required by the Liquidity Rule. The SEC noted that providing funds with flexibility to include the discussion in either the annual or semi-annual report enables funds to synchronize the production of the disclosure with the board’s annual review of liquidity risk management programs, and thereby reduces the costs associated with producing the disclosure. According to the adopting release, the discussion “generally should provide a high level summary of the report that must be provided to the fund’s board under [the Liquidity Rule] addressing the operation of the fund’s liquidity risk management program and the adequacy and effectiveness of its implementation.”

The SEC further explained that the discussion “should provide investors with enough detail to appreciate the manner in which a fund manages its liquidity risk, and could, but is not required to, include discussion of the role of the classification process, the 15% illiquid investment limit, and the [highly liquid investment minimum] in the fund’s liquidity risk management process.” The SEC noted that a fund may consider including in the discussion “particular liquidity risks that it faced over the past year, such as significant redemptions, changes in the overall market liquidity of the investments the fund holds, or other liquidity risks, and explain how those risks were managed or addressed.” The SEC also noted that a fund may wish to provide in the discussion “context and other supplemental information about how liquidity risk is managed in relation to other investment risks of the fund” or “other empirical data metrics such as the fund’s bid-ask spreads, portfolio turnover, or shareholder concentration issues (if any) and their effect on the fund’s liquidity risk management.”

Classifying an Investment under Multiple Liquidity Buckets

As previously noted, the Liquidity Rule requires a fund to classify each of its portfolio holdings into one of four liquidity buckets and to report the liquidity classification of each portfolio holding on Form N-PORT on a monthly basis. The amendments to Form N-PORT permit a fund to classify a portfolio holding into two or more liquidity buckets in the following three circumstances: (i) if a fund has multiple sub-advisers with differing liquidity views; (ii) if portions of the position have differing liquidity features that justify treating the portions separately;5 or (iii) if the fund chooses to classify the position through evaluation of how long it would take to liquidate the entire position (rather than basing it on the sizes it would reasonably anticipate trading).6 If a fund chooses to classify an investment under multiple liquidity buckets, the fund is required to indicate which of these three circumstances prompted the multiple classifications, and the fund is permitted to provide additional context (in the explanatory notes section of Form N-PORT) regarding the circumstance that led to the multiple classifications.

Disclosing Cash and Certain Cash Equivalents

Consistent with the proposing release, the amendments add a new sub-item to Form N-PORT, requiring a fund to report its cash and cash equivalents that are not already required to be reported on Part C (Schedule of Portfolio Investments) or Part D (Miscellaneous Securities) of the form.7 The adopting release indicated that access to this information will enable the SEC to monitor a fund’s compliance with: the fund’s stated highly liquid investment minimum; and trends in the fund industry regarding cash holdings. The adopting release indicates that this information about cash holdings will provide the SEC with a window into “other activities that a fund is experiencing, including [the fund’s] net inflows and outflows.”

Exemptive Relief and Continuing Evaluation for Further Changes

In 2017, the U.S. Department of the Treasury recommended that the SEC embrace a “principles-based approach to liquidity risk management rulemaking and any associated bucketing requirements.”8 In the release proposing the amendments to the liquidity rule disclosure requirements, the SEC requested comments on the Treasury Department’s recommendations. A number of industry participants submitted comment letters that continued to question the benefits of the specific liquidity classification requirements under the Liquidity Rule, and some industry participants noted that they would continue to maintain their existing liquidity risk management practices alongside the liquidity risk management programs required under the rule. In response, the SEC stated that “funds that believe they would have to maintain dual liquidity classification programs as part of their liquidity risk management may choose to seek an exemption from the [SEC] from the classification requirements of [the Liquidity Rule] if they believe that their existing systems would effectively accomplish the [SEC]’s stated goals.” However, the SEC declined to state whether, under what circumstances, and subject to what conditions, it would grant such relief.

However, in response to industry commenters, the SEC noted in the adopting release that the SEC staff will continue to evaluate the implementation and disclosure of liquidity classifications, and seeks to receive industry feedback. The SEC stated that it expects the staff’s evaluation to include consideration of a “year’s worth” of liquidity classification information and to consider: “(i) the costs and benefits of [the Liquidity Rule] and its associated classification requirements; (ii) whether there should be public dissemination of fund-specific liquidity classification information; (iii) whether the [SEC] should propose amendments to [the Liquidity Rule] to move to a more principles-based approach in light of this evaluation; (iv) and whether the [SEC] should propose to require certain empirical data metrics be disclosed.” The SEC indicated that, after this evaluation, it expects the staff to advise whether further changes are recommended.

Compliance Dates

  • Liquidity Disclosures on Form N-PORT. Compliance with the new Form N-PORT amendments corresponds to the revised compliance dates the SEC previously adopted9 and depends on the fund’s asset size and/or the asset size of its related fund complex. For larger funds that, combined with other funds in the same complex, have net assets of US$1 billion or more as of the end of the most recent fiscal year (larger fund complexes), the compliance date will be June 1, 2019. For smaller funds that, combined with other funds in the same complex, have net assets below US$1 billion as of the end of the most recent fiscal year (smaller fund complexes), the compliance date will be March 1, 2020.
  • Disclosure about the Operation and Effectiveness of the Liquidity Risk Management Program. Similar to the compliance date for the liquidity disclosures on Form N-PORT, the compliance date for the Form N-1A disclosure requirements varies based on the fund’s asset size. In response to comments received on the proposed rule, the SEC deferred the compliance dates for the new shareholder report amendments until after a fund has had at least a year’s experience operating its liquidity risk management program under the Liquidity Rule. For larger fund complexes, the compliance date will be December 1, 2019; for smaller fund complexes, the compliance date will be June 1, 2020. Shareholder reports distributed after the relevant compliance dates must include the new narrative disclosure.
  • Footnotes

    1) Investment Company Liquidity Disclosure, Release No. IC-33142 (June 28, 2018).

    2) For further information regarding Form N-PORT, please refer to the following Dechert OnPoints: SEC Adopts Rules and Forms to Modernize Reporting Requirements for Registered Investment Companies; and SEC Announces Delay in Form N-PORT Filing Requirements.

    3) For further information regarding the Liquidity Rule and related guidance, please refer to the following Dechert OnPoints: SEC Adopts New Rules and Rule Amendments to Require Registered Open-End Investment Companies to Establish Liquidity Risk Management Programs and Permit Them to use “Swing Pricing”; SEC Staff Issues Liquidity Rule Frequently Asked Questions; and SEC Delays Compliance Dates for Certain Liquidity Rule Requirements, SEC Staff Issues Responses to Second Set of Liquidity Rule FAQs.

    4) The adopting release provides, however, that a fund may be required to discuss in management’s discussion of fund performance any liquidity events that materially affected the fund’s performance. The discussion should include sufficient information so that investors “can understand the liquidity event, how it affected performance, and any other relevant market conditions.” In addition to the liquidity-related disclosures included in a shareholder report, the SEC noted in the adopting release that a fund is required to disclose liquidity risk in the fund’s prospectus if that is a principal risk of the fund.

    5) The SEC explained that differing liquidity characteristics may occur, for example, if a fund holds a put option on a portion of a portfolio holding, or if a fund purchases restricted securities in a private offering and makes additional purchases of the same security in the public market.

    6) The SEC clarified in the adopting release that, in addition to using multiple classifications for reporting purposes on Form N-PORT, funds may use multiple classifications in their liquidity risk management program for compliance purposes.

    7) The SEC noted that certain fund investments (e.g., in money market funds) may be reported on Part C or Part D of Form N-PORT and could be reasonably categorized as cash equivalents. To prevent double counting these investments, the SEC limited reporting under the new sub-item to those cash equivalents that are not already reported on Parts C or D (e.g., accounts receivable).

    8) A Financial System That Creates Economic Opportunities: Asset Management and Insurance, U.S. Department of the Treasury, October 2017. In the report, the Treasury Department noted the importance of liquidity risk management programs for investment companies for “effective fund management and the health of the financial markets,” but recommended that the SEC postpone the liquidity classification requirement and replace it with a less prescriptive, principles-based approach to liquidity risk management. For an overview of the Treasury Department’s report, please refer to Dechert OnPoint, Treasury’s Third Report on Financial System Regulation Focuses on the Asset Management and Insurance Industries.

    9) The SEC previously extended the compliance dates for certain Form N-PORT reporting requirements, by adopting an interim final rule on February 21, 2018. For further information, please refer to Dechert OnPoint, SEC Delays Compliance Dates for Certain Liquidity Rule Requirements; SEC Staff Issues Responses to Second Set of Liquidity Rule FAQs.


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