News & Analysis as of

Liquidity Risk Management Rule

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

Asset Management Regulatory Roundup - July 2017 - Issue 2

by Dechert LLP on

A compact summary of the most recent regulatory developments relevant to the UK asset management industry. This issue includes details on the updated Q&As published by ESMA in relation to the AIFMD and UCITS, IOSCO's...more

Investment Funds Update: Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

by Dechert LLP on

AMF Priorities in the EMIR Review - The Autorité des Marchés Financiers (the “AMF”, the French financial markets authority) published two position papers on 2 May 2017 relating to the EMIR review...more

Fund Liquidity Risk Management Task Force

by Dechert LLP on

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

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

by Dechert LLP on

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

Investment Management Legal + Regulatory Update – February 2017

by Morrison & Foerster LLP on

REGULATION - DOL Issues Additional Guidance on Fiduciary Rule - On January 13, 2017, the U.S. Department of Labor (“DOL”) issued a second set of guidance on its new fiduciary rules, which are scheduled to become...more

Regulatory Update and Recent SEC Enforcement Actions

by Blank Rome LLP on

FINRA Bar Results from Assertion of Fifth Amendment Right against Self-Incrimination in Criminal Action - On October 5, 2016, the Financial Industry Regulatory Authority (“FINRA”) barred an indicted investment adviser,...more

SEC Adopts Liquidity Risk Programs for Funds

by Carlton Fields on

On October 13, the SEC adopted rule reforms designed to improve liquidity risk management by open-end funds. Liquidity Risk Management Programs - Under the reforms, mutual funds (excluding money market funds) and...more

FINRA’s 2017 Regulatory & Exam Priorities

by Burr & Forman on

On January 4, new President and CEO Richard Cook issued FINRA’s Annual Regulatory and Examination Priorities Letter. This year’s list in summary is: New for 2017: Targeted electronic off-site reviews “on select...more

7 Securities Law and Regulatory Changes Likely to be Considered During the Trump Administration

On November 8, 2016, political power in United States shifted in an unexpected and unprecedented way. As of January 20, 2017, Republicans will hold the White House and both Houses of Congress. President-elect Donald Trump...more

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

Time to Get With the (Liquidity Risk) Program: SEC Issues Liquidity Risk Management Rule for Open-End Funds

by K&L Gates LLP on

On October 13, 2016, the Securities and Exchange Commission (“SEC”) adopted new Rule 22e-4 (“Liquidity Rule”) under the Investment Company Act of 1940 (“1940 Act”), which requires registered open-end funds, including open-end...more

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

by 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

"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

The Financial Report, Volume 5, Number 20 - October 2016

by DLA Piper on

With the general election now less than two weeks away, it is more apparent than ever that Americans often are sharply divided about how best to achieve certain goals, even if we agree on the goals we are trying to achieve....more

SEC Finalizes Rules Requiring Liquidity Risk Management by Open-End Funds

by Ropes & Gray LLP on

In an October 13, 2016 release (the “Release”), the SEC adopted Rule 22e-4 (the “Rule”) and published new disclosure and data reporting requirements. Most notably...more

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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