News & Analysis as of

Liquidity Risk Management Rule

Investment Services Regulatory Update - April 2018

by 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

Liquidity Management Rule – Delays and Revisions

by Proskauer Rose LLP on

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

SEC Delays Certain Liquidity Rule Requirements and Issues Guidance Regarding Illiquid Security Determinations

by K&L Gates LLP on

On February 22, 2018, the Securities and Exchange Commission (“SEC”) adopted an interim rule (“Interim Rule”) that revised compliance dates for certain provisions of Rule 22e-4 under the Investment Company Act (the “Liquidity...more

SEC Proposes Rule Changes to Public Liquidity Risk Management Disclosures

by 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

Division of Investment Management Issues Second Round of FAQs on Liquidity Risk Management Programs

by K&L Gates LLP on

On February 21, 2018, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management (the “Division”) issued additional guidance related to Rule 22e-4 under the Investment Company Act (“Liquidity Rule” or...more

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

by Dechert LLP on

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

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

by 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

SEC Proposes Amendment to Liquidity Rule

On March 14, 2018, the SEC proposed an amendment to the Liquidity Rule. As adopted, the Liquidity Rule requires open-end investment companies to establish a written liquidity risk management program. As part of this program...more

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

by Shearman & Sterling LLP on

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

Orrick's Financial Industry Week In Review

Home Mortgage Disclosure Act: FFIEC's Revised 'A Guide to HMDA Reporting: Getting It Right!' On March 14, 2018, the Office of the Comptroller of the Currency published an updated resource providing guidance for complying...more

Investment Services Regulatory Update - March 2018

by 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

SEC Proposes Targeted Changes to Public Liquidity Risk Management Disclosure

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

SEC Extends Compliance Date for Some Requirements of the Liquidity Risk Management Rule and Related Disclosure Requirements –...

by Ropes & Gray LLP on

On February 22, 2018, the SEC adopted an interim final rule (the “IFR”) that extends, for six months, the compliance date for some of the requirements of Rule 22e-4 under the 1940 Act (the “Liquidity Rule”) and related...more

SEC Extends Compliance Deadline for Certain Aspects of Liquidity Risk Management Programs Under the Investment Company Act

On February 22, 2018, the Securities and Exchange Commission (“SEC“) announced that it is adopting an interim final rule that provides a six-month extension for compliance with certain requirements of Rule 22e-4 regarding a...more

SEC Extends Deadline for Fund Compliance With Classification-Related Elements of Liquidity Risk Management Rule

This week, the SEC adopted an interim rule (the Interim Rule) delaying by six months the compliance dates for classification-related aspects of Liquidity Risk Management Program requirements pursuant to Rule 22e-4 (the Rule)...more

Asset Management Regulatory Roundup - February 2018 - Issue 3

by Dechert LLP on

A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details of the situation for financial services rules and regulations during the Brexit...more

SEC Releases Liquidity Rule FAQs

by Morrison & Foerster LLP on

The staff of the SEC’s Division of Investment Management released this week a series of frequently asked questions (FAQs) regarding new Rule 22e-4 (the “Liquidity Rule”). The Liquidity Rule requires non-money market mutual...more

Investment Services Regulatory Update - December 2017

by Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - NEW RULES - SEC Delays Form N-PORT EDGAR Filing Requirement by Nine Months - On December 8, 2017, the SEC adopted a temporary rule (the Temporary Rule) delaying by...more

SEC Announces Delay in Form N-PORT Filing Requirements

by Dechert LLP on

The U.S. Securities and Exchange Commission (SEC) on December 8, 2017 issued a temporary final rule (Temporary Rule) that provides a nine-month delay to the dates by which certain registered investment companies (funds) must...more

Treasury’s Third Report on Financial System Regulation Focuses on the Asset Management and Insurance Industries

by Dechert LLP on

The U.S. Department of the Treasury (Treasury) recently released a report examining the regulatory framework for the asset management and insurance industries (Report). The Report is the third in a series of four reports that...more

Trump Administration Issues Guidance on Asset Management and Insurance Regulation

On Oct. 26, 2017, the U.S. Treasury Department (Treasury) released the latest installment in a series of reports on financial regulation required by the president’s Feb. 3 executive order on the financial system....more

Treasury Report Addresses Regulatory Approaches Affecting Investment Companies and Their Advisers

by Pepper Hamilton LLP on

As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more

SFC Highlights Deficiencies in Asset Management Industry

• The SFC has identified nine common areas of non-compliance in managing funds and discretionary accounts. • The SFC urged licensed corporations to review their existing internal control procedures and operational...more

Regulators Tackle Board Effectiveness and Overdrafts

by Bryan Cave on

Host Jonathan Hightower is joined by Ken Achenbach to discuss this week's proposed guidance from the Federal Reserve on the effectiveness of bank boards. In addition, at the outset of the episode Jonathan and Ken reviewed...more

ICI Requests Delay and Re-Examination of Liquidity Risk Management and Reporting Modernization Rules

by Dechert LLP on

In a letter to U.S. Securities and Exchange Commission (SEC) Chairman Jay Clayton, the Investment Company Institute (ICI) formally requested a delay and re-examination of certain elements of Rule 22e-4 under the Investment...more

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