News & Analysis as of

Form N-PORT Disclosure Requirements

Dechert LLP

SEC Expands Scope of Fund “Names Rule”

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The Securities and Exchange Commission recently adopted significant changes to Rule 35d-1 under the Investment Company Act of 1940 (Names Rule), as well as certain forms and disclosure requirements on September 20, 2023...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Seward & Kissel LLP

SEC Adopts Amendments to the Fund “Names Rule” - November 2023

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The Securities and Exchange Commission (the “SEC”) recently adopted amendments1 to Rule 35d-1 under the Investment Company Act of 1940, the fund “Names Rule” (“Amendments”). In the Release, the SEC noted that the Amendments...more

Goodwin

SEC Adopts Rule Enhancements to Prevent Misleading or Deceptive Investment Fund Names

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On September 20, 2023, the US Securities and Exchange Commission (the “SEC”) voted, by a 4-1 vote, to adopt certain amendments (the “final rule” or the “amendments”) to Rule 35d-1 (the “Names Rule”) under the Investment...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

Troutman Pepper

SEC Grants Relief to Funds and Advisers Related to COVID-19 Outbreak

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As a result of the current and potential effects of COVID-19, the SEC has relaxed certain requirements of the Investment Company Act of 1940 and the Investment Advisers Act of 1940 and rules under the Acts....more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2019

In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more

A&O Shearman

SEC Modifies Form N-PORT Filing Timeline

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In what will be a welcome reprieve, the Securities and Exchange Commission eased compliance burdens for most mutual funds, ETFs and closed-end funds to file portfolio holdings reports on Form N-PORT. The SEC pushed back the...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

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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

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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

Kramer Levin Naftalis & Frankel LLP

SEC Acts on Liquidity Disclosure Rules and Proposes Easing Regulation of ETF Launches

At an open meeting on June 28, 2018, the SEC adopted liquidity disclosure amendments and proposed new rules to ease the approval process for new exchange-traded funds (ETFs). ...more

Vedder Price

Investment Services Regulatory Update - April 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...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

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

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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

Troutman Pepper

SEC Modernization in Plain English: Decoding the Regulation

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Practical points on managing SEC Modernization. INTRODUCTION - On October 13, 2016, the Securities and Exchange Commission (SEC) issued its final Investment Company Reporting Modernization rules and forms for the...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

K&L Gates LLP

SEC Issues Investment Company Reporting Modernization Rules

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On October 13, 2016, the Securities and Exchange Commission (“SEC”) adopted significant reforms under the Investment Company Act of 1940, as amended (“1940 Act”), that impose extensive new disclosure and reporting obligations...more

Ballard Spahr LLP

Investment Management Update

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Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Goodwin

Regulatory Update: SEC Adopts New Requirements for Fund Liquidity Risk Management and Amendments to Permit the Use of “Swing...

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On October 13, 2016, the U.S. Securities and Exchange Commission (SEC) unanimously adopted regulatory changes that require open-end funds, including mutual funds and exchange-traded funds (ETFs), to establish liquidity risk...more

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