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SEC Amends Liquidity Rule Reporting and Disclosure Requirements

On June 28, 2018, the Securities and Exchange Commission (“SEC”) amended certain disclosure requirements related to the “Liquidity Rule” — Rule 22e-4 — for open-end funds (except money market funds) registered under the...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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