News & Analysis as of

Liquidity Risk Management Disclosure Requirements

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

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Goodwin

Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities

Goodwin on

Regulatory Developments - Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities - On February 23, the Federal Reserve, FDIC and OCC (the Agencies) issued a “Joint...more

Goodwin

SEC Proposes Regulatory Changes to Open-End Fund Liquidity Requirements

Goodwin on

On November 2, 2022, the U.S. Securities and Exchange Commission (“SEC”), by a vote of 3-2, proposed amendments to rules under the Investment Company Act of 1940 that would modify the existing liquidity risk management...more

Snell & Wilmer

Annual Reporting Considerations

Snell & Wilmer on

COVID-19 Considerations. Following the onset of the COVID-19 pandemic, the SEC has twice issued guidance for public companies addressing disclosure considerations in light of COVID-19.1 This guidance remains useful as...more

White and Williams LLP

Underwriting D&O Risks for Coronavirus (COVID-19)-Related Exposures

White and Williams LLP on

Among the many dramatic changes to Americans’ personal and professional lives during the past few weeks has been the noticeable absence of established guidelines and information on how to conduct business in this...more

K&L Gates LLP

SEC Amends Liquidity Rule Reporting and Disclosure Requirements

K&L Gates LLP on

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

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

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

Vedder Price

Investment Services Regulatory Update - November 2017

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues No-Action Letters to Facilitate Cross-Border Compliance with the Research “Unbundling” Provisions of the European...more

BCLP

Regulators Tackle Board Effectiveness and Overdrafts

BCLP 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

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

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

Dechert LLP

SEC Proposes New Liquidity Management Rules for Mutual Funds and ETFs

Dechert LLP on

Recently, the U.S. Securities and Exchange Commission unanimously approved proposals that would require open-end funds, including mutual funds and exchange-traded funds, to comply with new liquidity management rules. The...more

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