News & Analysis as of

Disclosure Requirements Securities and Exchange Commission (SEC) Liquidity Risk Management Rule

Kramer Levin Naftalis & Frankel LLP

SEC Provides Guidance on Liquidity Rule Compliance

On Aug. 28, 2024, the SEC issued a release providing guidance on certain aspects of open-end funds’ compliance with Rule 22e-4, i.e., the Liquidity Rule, under the Investment Company Act of 1940 (the Guidance). The Guidance...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - August 2023

Closed-End Fund Activism Update - Activist investors continue to take large positions in closed-end funds and engage in disruptive activity that may be harmful to long-term shareholders of retail closed-end funds. This...more

Dechert LLP

SEC Proposes Mandated Swing Pricing, Hard Close and Fundamental Changes to Liquidity Rule

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The Securities and Exchange Commission on November 2, 2022 proposed significant revisions to its rules governing open-end investment company liquidity risk management and swing pricing. The proposal would also update related...more

K&L Gates LLP

Session I - Industry Regulatory Developments: 2019 Boston Investment Management Conference

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AGENDA - - Liquidity Rule Implementation - ETFs: Final Rule Update and Active NonTransparent ETF Developments - Fund of Funds Rule Proposal - Board Outreach and Fund Governance Update - SEC Examination Update,...more

K&L Gates LLP

SEC Amends Liquidity Rule Reporting and Disclosure Requirements

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On June 28, 2018, the Securities and Exchange Commission (“SEC”) amended certain disclosure requirements related to the “Liquidity Rule” — Rule 22e-4 — for open-end funds (except money market funds) registered under the...more

Dechert LLP

SEC Amends Investment Company Liquidity Rule Disclosure Requirements

Dechert LLP on

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,...more

Kramer Levin Naftalis & Frankel LLP

Public liquidity-related disclosure requirements adopted for open-end funds

The SEC adopted amendments to public liquidity-related disclosure requirements for certain open-end funds, requiring them to discuss the operation and effectiveness of their liquidity risk management programs within their...more

Orrick - Finance 20/20

SEC Adopts Targeted Changes to Public Liquidity Risk Management Disclosure

Orrick - Finance 20/20 on

On June 28, 2018, the Securities and Exchange Commission (“SEC“) approved “amendments to public liquidity-related disclosure requirements for certain open-end funds… [wherein] funds would discuss in their annual or...more

A&O Shearman

SEC Replaces Requirement to Disclose Liquidity Buckets With Requirement to Disclose Effectiveness of Liquidity Risk Management...

A&O Shearman on

In a split vote on June 28, 2018, the Securities and Exchange Commission adopted a new rule to require certain open-end investment companies to disclose in their annual or semi-annual shareholder reports information about the...more

Ballard Spahr LLP

Investment Management Update

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Regulation BI, Form CRS, Adviser or Advisor, and Fiduciary Duties of Adviser - In a flurry of proposed rulemaking that added up to more than 900 pages of reading material, the Securities and Exchange Commission (SEC)...more

Goodwin

Recent Series of Regulatory Developments Regarding Implementation of the SEC’s Liquidity Rule and Related Requirements

Goodwin on

The U.S. Securities and Exchange Commission and its staff recently have taken a series of regulatory actions regarding the implementation of the new liquidity rule, including (1) a proposal to amend certain reporting and...more

Vedder Price

Investment Services Regulatory Update - April 2018

Vedder Price on

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...more

Proskauer Rose LLP

Liquidity Management Rule – Delays and Revisions

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On October 13, 2016, the Securities and Exchange Commission (the "SEC") adopted Rule 22e-4 (the "Liquidity Rule") under the Investment Company Act of 1940, as amended, to require each registered open-end management investment...more

K&L Gates LLP

SEC Proposes Rule Changes to Public Liquidity Risk Management Disclosures

K&L Gates LLP on

On March 14, 2018, the Securities and Exchange Commission (“SEC”) proposed amendments to public liquidity-related disclosure requirements mandated by Rule 22e-4 under the Investment Company Act (the “Liquidity Rule”). ...more

Dechert LLP

Financial Services Quarterly Report - First Quarter 2018: SEC Liquidity Rule Guidance and Rulemaking – A More Flexible Approach

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Adopted by the U.S. Securities and Exchange Commission (SEC) in 2016, Rule 22e-4 under the Investment Company Act of 1940 (Liquidity Rule) has presented the fund industry with thorny interpretive questions and compliance...more

Dechert LLP

SEC Proposes Changes to Investment Company Liquidity Risk Management Liquidity Classification Disclosures

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC) on March 14, 2018 proposed a rule (Proposed Rule) that would: (i) eliminate or modify certain disclosure requirements of Form N-PORT; and (ii) add a new disclosure requirement...more

A&O Shearman

The SEC’s Liquidity Rule: Where Do We Stand?

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In October 2016, a unanimous Securities and Exchange Commission adopted a package of rules for Investment Company Liquidity Risk Management Programs (collectively, the “Liquidity Rule”) and set a deadline for implementation...more

Vedder Price

Investment Services Regulatory Update - March 2018

Vedder Price on

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...more

Orrick - Finance 20/20

SEC Proposes Targeted Changes to Public Liquidity Risk Management Disclosure

Orrick - Finance 20/20 on

On March 14, 2018, the Securities and Exchange Commission (“SEC“) “proposed amendments to public liquidity-related disclosure requirements for certain open-end investment management companies.” The proposed amendments, and...more

Dechert LLP

Fund Liquidity Risk Management Task Force

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Implementing the U.S. Securities and Exchange Commission’s (SEC) fund liquidity risk management rules presents distinct challenges for open-end mutual funds and exchange-traded funds (ETFs), and compliance with the rules will...more

Dechert LLP

Upcoming Compliance Deadlines for Registration Statement and Shareholder Report Disclosures under Liquidity Risk Management and...

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The initial compliance dates are rapidly approaching for new disclosure requirements adopted by the U.S. Securities and Exchange Commission (SEC) for registered investment company (funds). All initial registration statement...more

Eversheds Sutherland (US) LLP

SEC Adopts Liquidity Risk Management Rules for Mutual Funds and Other Open-End Investment Companies 

On October 13, 2016, the SEC approved new Rule 22e-4 under the Investment Company Act of 1940, as amended (the 1940 Act), which will require certain open-end investment companies other than money market funds, to adopt and...more

Dechert LLP

SEC Adopts New Rules and Rule Amendments to Require Registered Open-End Investment Companies to Establish Liquidity Risk...

Dechert LLP on

The U.S. Securities and Exchange Commission (SEC or Commission) has unanimously adopted new rules and rule amendments to require registered open-end investment companies (including exchange traded funds and exchange-traded...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Adopts Liquidity Risk Management Rules for Mutual Funds and Exchange-Traded Funds"

On October 13, 2016, the SEC voted to adopt new and amended rules and forms intended to enhance and standardize liquidity risk management by mutual funds and exchange-traded funds, which will likely have a broad impact on...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more

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