SEC Liquidity Rule Guidance and Rulemaking – A More Flexible Approach

April 04, 2018
Financial Services Quarterly Report: First Quarter 2018

The U.S. SEC's “Liquidity Rule” under the Investment Company Act of 1940 has presented the fund industry with thorny interpretive questions and compliance challenges. Recently, the SEC and the staff of its Division of Investment Management addressed some of these questions and challenges through new rulemaking and guidance, including through the issuance of responses to frequently asked questions. Also, the SEC delayed the compliance deadline for certain elements of the Liquidity Rule and issued a proposed rule that would modify certain liquidity-related disclosure requirements.

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