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 exchange-traded funds (“ETFs”) but excluding money market funds and closed-end funds, to establish and implement written Liquidity Risk Management Programs (“LRMPs”).[1] The SEC also amended fund reporting forms, and adopted new forms, mandating disclosure of liquidity-related information to the SEC and to the public.[2] In a separate adopting release, the SEC adopted new paragraph (a)(3) of Rule 22c-1 under the 1940 Act (“Swing Pricing Rule”), which permits open-end funds, other than money market funds and ETFs, to use “swing pricing.”[3] Swing pricing allows a fund to adjust its net asset value (“NAV”) to pass on the costs associated with heavy trading activity to purchasing or redeeming shareholders.