News & Analysis as of

Open-Ended Fund Companies (OFCs) Securities and Exchange Commission (SEC) Liquidity Risk Management Rule

Lowenstein Sandler LLP

Gensler Warns of Increased SEC Requirements for Private Funds

On May 25, 2023, Gary Gensler, Chairperson of the U.S. Securities and Exchange Commission (SEC), spoke at an Investment Company Institute leadership conference and discussed SEC proposals that address potential instability in...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

A&O Shearman

SEC Replaces Requirement to Disclose Liquidity Buckets With Requirement to Disclose Effectiveness of Liquidity Risk Management...

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In a split vote on June 28, 2018, the Securities and Exchange Commission adopted a new rule to require certain open-end investment companies to disclose in their annual or semi-annual shareholder reports information about the...more

Dechert LLP

SEC Proposes Changes to Investment Company Liquidity Risk Management Liquidity Classification Disclosures

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The U.S. Securities and Exchange Commission (SEC) on March 14, 2018 proposed a rule (Proposed Rule) that would: (i) eliminate or modify certain disclosure requirements of Form N-PORT; and (ii) add a new disclosure requirement...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

Eversheds Sutherland (US) LLP

SEC Adopts Liquidity Risk Management Rules for Mutual Funds and Other Open-End Investment Companies 

On October 13, 2016, the SEC approved new Rule 22e-4 under the Investment Company Act of 1940, as amended (the 1940 Act), which will require certain open-end investment companies other than money market funds, to adopt and...more

K&L Gates LLP

Time to Get With the (Liquidity Risk) Program: SEC Issues Liquidity Risk Management Rule for Open-End Funds

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On October 13, 2016, the Securities and Exchange Commission (“SEC”) adopted new Rule 22e-4 (“Liquidity Rule”) under the Investment Company Act of 1940 (“1940 Act”), which requires registered open-end funds, including open-end...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

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2015: And a Partridge in a Pear Tree: Top 12 Regulatory Heads-up for the...

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1st Day of Christmas – UCITS V* - The UCITS V Directive (UCITS V) introduces specific provisions on: - (i) eligibility, liability and delegation of depositaries; - (ii) remuneration policies; and ...more

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