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...

IM Director's Recent Remarks on Standards of Conduct & Liquidity Risk Management

May 25, 2018 8:30:21 AM

IM Director's Recent Remarks on Standards of Conduct & Liquidity Risk Management by Peter Michael Allen   Recently, Dalia Blass, Director of the SEC’s Division of Investment Management (IM) commented about the standards of conduct for investment professionals and liquidity risk management for open-end funds, including mutual funds and exchange-traded funds (ETFs). Given that the SEC recently submi...

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 ...

Liquidity is Out, ETFs are In

Apr 7, 2018 4:43:26 PM

The SEC’s stance on its not-yet-effective liquidity rule appears fluid, as commissioners push to abandon part of the rule and certain division heads move on to other topics. At the 2018 ICI Mutual Funds and Investment Management conference, Commissioner Hester Peirce and division director Dalia Blass signaled the possible end of the liquidity rule as an emphasis of the SEC. Commissioner Hester not...