News & Analysis as of

Liquidity Securities and Exchange Commission (SEC) 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

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

Dechert LLP

SEC Proposes Mandated Swing Pricing, Hard Close and Fundamental Changes to Liquidity Rule

Dechert LLP on

The Securities and Exchange Commission on November 2, 2022 proposed significant revisions to its rules governing open-end investment company liquidity risk management and swing pricing. The proposal would also update related...more

Pillsbury Winthrop Shaw Pittman LLP

SEC Streamlines Financial Disclosure Requirements under Regulation S-K for Reporting Companies

The amendments are designed to increase focus on material information while simplifying compliance efforts. The amendments eliminate the five-year selected financial data requirement, limit selected quarterly financial...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

Bracewell LLP

SEC Sends Warning Shot on COVID-Impact Disclosures

Bracewell LLP on

The Securities and Exchange Commission fired a warning shot last week to all public companies about the quality and accuracy of disclosures made regarding the impact of the COVID-19 pandemic on business operations. On...more

Fenwick & West LLP

SEC Issues Final Rules Amending MD&A Requirements and Other Financial Disclosures

Fenwick & West LLP on

The U.S. Securities and Exchange Commission has issued final rules adopting amendments to certain financial disclosure requirements and to the disclosure required in Management’s Discussion and Analysis (MD&A). We previously...more

Goodwin

CFPB, FTC And 50 States Show Power In Numbers With Operation Corrupt Collector

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB), along with the Federal Trade Commission (FTC) and more than 50 federal and state law enforcement partners, announced Operation Corrupt Collector, a nationwide law...more

Katten Muchin Rosenman LLP

Second Quarter Reporting — Recent SEC Guidance on COVID-19-Related Disclosure

The 2019 novel coronavirus (COVID-19) pandemic continues to have an impact on the operations of nearly every business and business sector. Reporting companies must evaluate how they disclose the effects of the pandemic,...more

White & Case LLP

Practical Tips to Prepare for Upcoming Quarterly Disclosures

White & Case LLP on

As companies close their books on the second quarter and prepare their second quarter disclosures, it is important to assess the continuing impact of COVID-19 on businesses, employees and financial results and provide...more

Troutman Pepper

SEC’s COVID-19 Supplemental Guidance Reinforces the Importance of High-Quality Financial Reporting

Troutman Pepper on

On June 23, 2020, in light of the ongoing global COVID-19 pandemic, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance released CF Disclosure Guidance: Topic No. 9A (the Supplemental Guidance),...more

Akin Gump Strauss Hauer & Feld LLP

SEC’s Division of Corporation Finance Provides Updated Guidance on Disclosure Considerations Regarding Operations, Liquidity and...

On June 23, 2020, the Division of Corporation Finance (“Division”) of the Securities and Exchange Commission (SEC) provided additional guidance (“Topic No. 9A”) regarding disclosures about operations, liquidity and capital...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Staff, Chief Accountant Provide Additional Guidance Related to COVID-19

On June 23, 2020, the Division of Corporation Finance (the Division) of the U.S. Securities and Exchange Commission (SEC) issued CF Disclosure Guidance: Topic No. 9A (Guidance) on disclosures focusing on the impact of...more

Sullivan & Worcester

SEC Provides Additional Disclosure Considerations for Companies Impacted by Coronavirus (COVID-19) as the End of the Second...

Sullivan & Worcester on

On June 23, 2020, the SEC issued new guidance for companies’ disclosure considerations regarding operations, liquidity and capital resources in light of COVID-19. The guidance, which largely reiterates similar themes as the...more

Sullivan & Worcester

More SEC Guidance on COVID-19 Disclosure

Sullivan & Worcester on

The SEC staff has issued new guidance regarding companies’ disclosure considerations regarding operations, liquidity and capital resources in light of COVID-19. The guidance, which largely reiterates the same themes as the...more

K&L Gates LLP

Session I - Industry Regulatory Developments: 2019 Boston Investment Management Conference

K&L Gates LLP on

AGENDA - - Liquidity Rule Implementation - ETFs: Final Rule Update and Active NonTransparent ETF Developments - Fund of Funds Rule Proposal - Board Outreach and Fund Governance Update - SEC Examination Update,...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

As promised, the Fed on Wednesday announced “one of the most significant rollbacks of bank rules” since the White House changed hands in the form of a draft proposal that would loosen capital and liquidity requirements for...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

Dechert LLP

SEC Amends Investment Company Liquidity Rule Disclosure Requirements

Dechert LLP on

The U.S. Securities and Exchange Commission has adopted amendments to certain disclosure requirements of open-end investment companies – including exchange-traded funds, but excluding money market funds – (collectively,...more

Kramer Levin Naftalis & Frankel LLP

Public liquidity-related disclosure requirements adopted for open-end funds

The SEC adopted amendments to public liquidity-related disclosure requirements for certain open-end funds, requiring them to discuss the operation and effectiveness of their liquidity risk management programs within their...more

Kramer Levin Naftalis & Frankel LLP

SEC Acts on Liquidity Disclosure Rules and Proposes Easing Regulation of ETF Launches

At an open meeting on June 28, 2018, the SEC adopted liquidity disclosure amendments and proposed new rules to ease the approval process for new exchange-traded funds (ETFs). ...more

Goodwin

Recent Series of Regulatory Developments Regarding Implementation of the SEC’s Liquidity Rule and Related Requirements

Goodwin on

The U.S. Securities and Exchange Commission and its staff recently have taken a series of regulatory actions regarding the implementation of the new liquidity rule, including (1) a proposal to amend certain reporting and...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

Dechert LLP

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

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

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