Upcoming Compliance Deadlines for Registration Statement and Shareholder Report Disclosures under Liquidity Risk Management and Reporting Modernization Reforms

May 05, 2017

The initial compliance dates are rapidly approaching for new disclosure requirements adopted by the U.S. Securities and Exchange Commission (SEC) for registered investment company (funds). All initial registration statement filings and post-effective amendments to an effective registration statement must comply with the new requirements if filed on or after the specified compliance dates. In addition, shareholder reports filed after the applicable compliance date must comply with the amendments to Regulation S-X. In particular, funds will be required to include the following:

  • New prospectus disclosure regarding the timing of redemption payments and methods to satisfy redemptions – compliance date: June 1, 2017. Open-end funds must disclose additional information in their prospectuses included in initial registration statement filings on Form N-1A.
  • New disclosure requirements regarding securities lending activities – compliance date: August 1, 2017. Open-end funds must disclose certain information in their Statement of Additional Information (SAI) included in initial registration statement filings and post-effective amendments thereto. Closed-end funds must disclose such information in their shareholder reports.
  • New shareholder report disclosure regarding derivatives and certain other investments – compliance date: August 1, 2017. All registered funds must disclose certain additional information in their shareholder reports.

Funds and their advisers and service providers will need to begin preparing updated disclosures to address these requirements in advance of the applicable compliance dates. This OnPoint provides an overview of these requirements and highlights issues funds and their advisers and service providers may wish to take into consideration.

Read "Upcoming Compliance Deadlines for Registration Statement and Shareholder Report Disclosures under Liquidity Risk Management and Reporting Modernization Reforms."