News & Analysis as of

Liquidity Securities and Exchange Commission (SEC) Investment Company Act of 1940

Morgan Lewis

SEC Amends Registered Fund Reporting Requirements, Issues Guidance on Liquidity Risk Management Programs

Morgan Lewis on

The US Securities and Exchange Commission (SEC), by a 3-2 vote, recently adopted amendments to registered fund reporting requirements on Form N-PORT and Form N-CEN and provided guidance on open-end funds’ liquidity risk...more

Dechert LLP

SEC Enhances Reporting on Forms N-PORT & N-CEN; Issues Liquidity Guidance

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On August 28, 2024, the SEC, by a vote of three to two, adopted amendments (Amendments) to the current reporting requirements on Form N-PORT and Form N-CEN and provided guidance (Liquidity Rule Guidance) related to liquidity...more

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

K&L Gates LLP

US Asset Management Regulatory Year in Review 2023

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It is a dramatic understatement to describe 2023 as a busy year in the United States for asset management regulation. With 24 rules adopted and 18 new rules or rule amendments proposed, the US Securities and Exchange...more

Kilpatrick

SEC’s First Liquidity Rule Enforcement Action Signals New Focus

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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

Goodwin

SEC Adopts Reforms for Money Market Funds

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On July 12, 2023, the US Securities and Exchange Commission ("SEC") voted, by a 3-2 vote, to adopt money market fund reforms that will significantly impact the regulatory framework governing money market funds ("money funds"...more

Kramer Levin Naftalis & Frankel LLP

SEC Adopts Amendments to Money Market Fund Rules

On July 12, the Securities and Exchange Commission (Commission) adopted amendments to Rule 2a-7 governing money market funds under the Investment Company Act of 1940 (1940 Act). ...more

Goodwin

SEC Files First Enforcement Complaint Under Liquidity Rule

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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

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

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

Goodwin

SEC Proposes New Round of Money Market Fund Reforms

Goodwin on

On December 15, 2021, the U.S. Securities and Exchange Commission (the “SEC”) voted, by a 3-2 vote, to propose money market fund reforms that would significantly impact the regulatory framework governing money market funds...more

K&L Gates LLP

SEC Proposes Another Round of Money Market Fund Reforms

K&L Gates LLP on

I. EXECUTIVE SUMMARY - On 15 December 2021, the Securities and Exchange Commission (the SEC) proposed amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Proposed Rule), which...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Major Amendments to Money Market Fund Rules

On Dec. 15, 2021, the Securities and Exchange Commission (SEC) voted to propose amendments to certain rules governing money market funds under the Investment Company Act of 1940 (the 1940 Act). The SEC indicated that the...more

Goodwin

SEC Adopts Rule Providing New Regulatory Framework For Fund-Of-Funds

Goodwin on

In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more

Goodwin

SEC Adopts New Regulatory Framework For Fund-Of-Funds Arrangements

Goodwin on

On October 7, 2020, the Securities and Exchange Commission (the "SEC") adopted Rule 12d1-4 under (the "Rule") the Investment Company Act of 1940 (the "1940 Act") and related amendments designed to put in place a comprehensive...more

K&L Gates LLP

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

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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

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

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

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

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

SEC Staff Seeks Industry Engagement on Questions Regarding Development of Funds Holding Cryptocurrency-Related Products

Dechert LLP on

The Director of the U.S. Securities and Exchange Commission (SEC) Division of Investment Management has outlined concerns of the SEC Staff (Staff) with respect to the registration of funds that hold cryptocurrencies and...more

Dechert LLP

Fund Liquidity Risk Management Task Force

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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

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