The Liquidity Rule Finally Takes Shape!

Jul 13, 2018 8:54:29 AM

In May, we discussed eight things that you needed to know about the liquidity rule in this article. At that time, we noted that part of the rule was due to take effect in December 2018 for large fund families or June 2019 for smaller fund families. The parts that were delayed until 2019 included the liquidity classifications (i.e., the buckets) and the highly liquid minimum requirement.  More impo...

8 Things You Need to Know about the Liquidity Rule

May 11, 2018 4:30:33 AM

1. Its name. Most people simply refer to the rule as the “liquidity rule”, but its technical name is Rule 22e-4: Investment Company Liquidity Risk Management Programs. If the rule survives in any meaningful form, we should start a contest on whether the industry keeps calling it the liquidity rule or refers to it as Rule 22e-4. Think of Rule 38a-1 under the Investment Company Act. Some people may ...

Starting a Compliance Program

Apr 1, 2018 10:14:33 PM

In January 2018, The SEC’s Fort Worth regional office held a teleconference that summarized the SEC’s 2017 exam findings and its focus areas for 2018. The staff noted that some of the common weaknesses in compliance programs for investment advisers include: Failure to tailor written policies and procedures to the adviser’s business (i.e., generic compliance manuals). Failure to manage or disclose ...

The SEC is Nervous About Options

Mar 19, 2018 10:52:54 PM

Why is the SEC nervous? On February 23, 2018, Commissioner Kara M. Stein gave a speech at SEC Speaks in Washington, DC. During the speech, Commissioner Stein raised broad ethical and economic considerations regarding the rapid advances in financial product innovation, which appears to be accelerating as financial firms increasingly use technology to expand their product line and deepen their reach...