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A Deep Dive into Money Market Fund Liquidity Fees

Executive Summary - On 12 July 2023, the Securities and Exchange Commission (the SEC) adopted amendments to Rule 2a-7 under the Investment Company Act of 1940, as amended (the 1940 Act) (the Final Rule), which governs the...more

Out With the Old, in With the New – SEC Scraps Swing Pricing Proposal, Removes Redemption Gates, and Mandates Liquidity Fees for...

In a surprising change, the SEC heeded the cacophony of opposition to swing pricing, but instead threw the industry a curveball by requiring mandatory liquidity fees for institutional prime and institutional tax-exempt money...more

Registered Funds and the New ESG Rule Proposals: Everything You Wanted to Know (But Were Afraid to Ask)

EXECUTIVE SUMMARY - On 25 May 2022, the Securities and Exchange Commission (SEC) proposed a series of amendments (the Proposed Amendments) to rules and reporting forms, which purport to provide investors with additional...more

Proposed Money Market Fund Reforms Related to Negative Interest Rates Favor Conversion to Floating NAV and Prohibit Other...

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 governs the structure and...more

SEC Proposes Swing Pricing for Institutional Money Market Funds

SECTIONS - I. Introduction - II. Key Requirements for Swing Factor Implementation - III. When a Swing Factor Must Be Applied - IV. Calculation of the Swing Factor - V. The President’s Working Group 2020 White Paper and Prior...more

SEC Proposes Another Round of Money Market Fund Reforms

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

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