News & Analysis as of

Liquidity Risk Management Liquidity Risk Management Rule

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

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

Goodwin

SEC Files First Enforcement Complaint Under Liquidity Rule

Goodwin on

On May 5, 2023, the U.S. Securities & Exchange Commission filed its first enforcement complaint under Rule 22e-4 of the Investment Company Act of 1940, 17 C.F.R. § 270.22e-4 (the Liquidity Rule). The complaint was brought...more

Carlton Fields

SEC Would Mandate Swing Pricing: Badly Upending Most Funds’ Procedures

Carlton Fields on

In November 2022, the SEC published a proposal that would mandate “swing pricing” procedures for the purchase and redemption of shares of most open-end investment companies. The proposal, however, does not apply to...more

A&O Shearman

UK Prudential Regulator Launches Consultation on Asset Encumbrance Rules

A&O Shearman on

The U.K. Prudential Regulation Authority has launched a consultation on its proposed expectations of how firms manage prudential risks associated with asset encumbrance. The PRA’s expectations are relevant to all...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

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

SFC Circular to Strengthen Liquidity Risk Management of Its Authorized Funds

K&L Gates LLP on

The SFC published the “Circular to management companies of SFC-authorized funds on liquidity risk management” dated July 4, 2016 (the “Circular”), designed to provide guidance to the management companies (each a “Fund...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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