News & Analysis as of

Liquidity Securities and Exchange Commission (SEC) 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

Proskauer Rose LLP

SEC Brings First Liquidity Rule Enforcement Action Against Investment Adviser and Fund Board

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On May 5, 2023, the Securities and Exchange Commission ("SEC") filed charges against Pinnacle Advisors LLC ("Pinnacle Advisers"), an investment adviser, for allegedly aiding and abetting violations of Rule 22e-4 (the...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

Carlton Fields

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

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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

Morgan Lewis

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

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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

Dechert LLP

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

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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

Dechert LLP

Liquidity Rule Reminders in Light of Recent Market Turmoil

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As financial markets react to daily, dramatic news headlines concerning the coronavirus pandemic, an oil market price war, extraordinary government responses and the economic and financial fallout, funds and their liquidity...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

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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

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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

Nutter McClennen & Fish LLP

What Fund Directors May Ask About The New SEC Fund Liquidity Rule

As larger mutual fund groups plan for their December 1, 2018 compliance date under the SEC’s Fund Liquidity Rule,[1] what major judgment calls must they be prepared to answer for fund directors?  Here is a non-exhaustive list...more

Goodwin

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

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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

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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

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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

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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

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

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...

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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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