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Checked Swing—SEC Does Not Adopt "Swing Pricing" or a "Hard Close" for Now, but Only Provides Liquidity Guidance and Amendments to...

EXECUTIVE SUMMARY On 28 August, 2024, the Securities and Exchange Commission (SEC) adopted amendments to reporting forms for registered investment companies (funds) that will (1) require funds to file monthly (rather than...more

SEC Adopts New Rule 12d1-4 Overhauling Fund of Funds Arrangements--Are You Ready?

I. EXECUTIVE SUMMARY - On 7 October 2020, the Securities and Exchange Commission (the SEC) adopted new rule 12d1-4 (Rule 12d1-4) and related amendments under the Investment Company Act of 1940 (the 1940 Act) that it believes...more

Registered Fund Developments: 2019 New York Investment Management Conference

OVERVIEW - - Background - Overview of the Rule - Exemptions Granted by Rule - Changes Made by Rule to Current ETF Regulatory Scheme - Key Board Interests ...more

SEC Delays Certain Liquidity Rule Requirements and Issues Guidance Regarding Illiquid Security Determinations

On February 22, 2018, the Securities and Exchange Commission (“SEC”) adopted an interim rule (“Interim Rule”) that revised compliance dates for certain provisions of Rule 22e-4 under the Investment Company Act (the “Liquidity...more

SEC Proposes Rule Changes to Public Liquidity Risk Management Disclosures

On March 14, 2018, the Securities and Exchange Commission (“SEC”) proposed amendments to public liquidity-related disclosure requirements mandated by Rule 22e-4 under the Investment Company Act (the “Liquidity Rule”). ...more

Division of Investment Management Issues Second Round of FAQs on Liquidity Risk Management Programs

On February 21, 2018, the Securities and Exchange Commission’s (“SEC”) Division of Investment Management (the “Division”) issued additional guidance related to Rule 22e-4 under the Investment Company Act (“Liquidity Rule” or...more

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

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

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