News & Analysis as of

Liquidity Investment Company Act of 1940 Mutual Funds

Kilpatrick

SEC’s First Liquidity Rule Enforcement Action Signals New Focus

Kilpatrick on

On May 5, 2023, the Securities and Exchange Commission (the “SEC”) announced its first enforcement action against an investment adviser for violations of Rule 22e-4(b) (the “Liquidity Rule”) of the Investment Company Act of...more

Morgan Lewis

SEC Proposes Mandatory Swing Pricing for Mutual Funds and Revised Liquidity Requirements

Morgan Lewis on

On November 2, 2022, the US Securities and Exchange Commission (SEC), by a 3-2 party line vote, proposed amendments (the Proposal) to the liquidity risk management programs rule (Rule 22e-4) under the Investment Company Act...more

Dorsey & Whitney LLP

Crypto, Tech and Slow Evolution Forward

Dorsey & Whitney LLP on

Crypto currency continues to be debated - some believe in it; others do not. The decision by the founder of Tesla to exit the market recently seems to have added a new element, however. Now the question is if crypto is energy...more

Vedder Price

Investment Services Regulatory Update - February 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more

Dechert LLP

Fund Liquidity Risk Management Task Force

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

Goodwin

Summary of New SEC Requirements for Open-End Fund Liquidity Risk Management and Amendments to Permit Use of “Swing Pricing”

Goodwin on

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

A&O Shearman

New Liquidity and Swing Pricing Rules for US Mutual Funds

A&O Shearman on

On October 13, 2016, a unanimous US Securities and Exchange Commission adopted far-reaching rules intended to address mutual fund liquidity risks. On the same day and by a divided (two to one) vote, the SEC adopted new mutual...more

Goodwin

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

Goodwin on

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

K&L Gates LLP

U.S. SEC Proposes Liquidity Risk Management Programs, Optional “Swing Pricing,” and Liquidity Reporting for Mutual Funds and...

K&L Gates LLP on

On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more

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