News & Analysis as of

Mutual Funds Liquidity

Seward & Kissel LLP

SEC Staff Publish New Registered Fund Statistics Report

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Who may be interested: Registered Investment Companies; Boards of Directors; Investment Advisers - Quick Take: The staff of the SEC’s Division of Investment Management (“Staff”) has published a new report entitled...more

Carlton Fields

SEC Folds on Swing Pricing for Money Market Funds: Odds Lengthen Against Swing Pricing for Other Fun

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On July 12, the SEC adopted, on a 3–2 party line vote, so-called money market fund reforms. The reforms substitute a required redemption (liquidity) fee for proposed “swing pricing” for certain institutional money market...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

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

Dorsey & Whitney LLP

Crypto, Tech and Slow Evolution Forward

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Crypto currency continues to be debated - some believe in it; others do not. The decision by the founder of Tesla to exit the market recently seems to have added a new element, however. Now the question is if crypto is energy...more

Skadden, Arps, Slate, Meagher & Flom LLP

Federal Reserve Liquidity Programs to Support US Economy During COVID-19 Pandemic — Highlights for Funds and BDCs

In response to the ongoing market turmoil created by the coronavirus/COVID-19 pandemic, the Federal Reserve has established a number of market stability and liquidity programs, many of which may be of interest to funds (both...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

Carlton Fields

Implementation Delay and Q&As for Fund Liquidity Rule

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On February 21, the SEC approved a six-month extension for mutual funds to comply with the classification (bucketing) requirements and related elements of its new liquidity rule....more

Vedder Price

Investment Services Regulatory Update - February 2018

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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

Morrison & Foerster LLP

SEC Staff Raises Concerns Related to Cryptocurrency ETFs and Mutual Funds

On January 18, 2018, the Securities and Exchange Commission’s (SEC) Division of Investment Management broke its relative silence regarding the recent growth of cryptocurrencies and cryptocurrency-related products. While...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

Financial Services Weekly News - December 2016 #3

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Editor's Note - The End of “Too Big to Fail”? On December 15, the Board of Governors of the Federal Reserve System (Federal Reserve Board) adopted a final rule to strengthen the ability of government authorities to...more

Goodwin

Summary of New SEC Requirements for Open-End Fund Liquidity Risk Management and Amendments to Permit Use of “Swing Pricing”

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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

A&O Shearman

New Liquidity and Swing Pricing Rules for US Mutual Funds

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On October 13, 2016, a unanimous US Securities and Exchange Commission adopted far-reaching rules intended to address mutual fund liquidity risks. On the same day and by a divided (two to one) vote, the SEC adopted new mutual...more

Goodwin

Regulatory Update: SEC Adopts New Requirements for Fund Liquidity Risk Management and Amendments to Permit the Use of “Swing...

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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

Broker-Dealer Compliance + Regulation

SEC Approves New Liquidity Risk Management Rules; Swing Pricing Rules

The SEC today unanimously approved “transformational” new rules requiring liquidity risk management programs. The SEC also approved a swing pricing rule by a vote of 2-1, with Commissioner Piwowar voting against it. ...more

Broker-Dealer Compliance + Regulation

SEC Adopts New Reporting Rules for Mutual Funds

A split SEC today approved new rules addressing mutual fund disclosures and liquidity. Chair White and Commissioner Stein voted yes; Commissioner Piwowar voted no. Here are the highlights of the new reporting...more

Foley & Lardner LLP

A Compilation of Non-Enforcement and Enforcement Actions

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Non-Enforcement - Mutual Fund Directors Must Be Vigilant in Addressing Risks - In remarks to the Mutual Fund Directors Forum, SEC Chair Mary Jo White outlined some of the risks and challenges that mutual fund...more

Ballard Spahr LLP

Investment Management Update - April 2016

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Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...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

Dechert LLP

SEC Proposes New Liquidity Management Rules for Mutual Funds and ETFs

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Recently, the U.S. Securities and Exchange Commission unanimously approved proposals that would require open-end funds, including mutual funds and exchange-traded funds, to comply with new liquidity management rules. The...more

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