ARTICLE
16 March 2018

SEC Proposes Amendments To Open-End Fund Liquidity Reporting Requirements

CW
Cadwalader, Wickersham & Taft LLP

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The SEC proposed amendments to its rules governing liquidity risk disclosure requirements for open-end funds. The rules were initially adopted in October 2016.
United States Corporate/Commercial Law

The SEC proposed amendments to its rules governing liquidity risk disclosure requirements for open-end funds. The rules were initially adopted in October 2016.

The amendments would require a fund to include in its annual report a narrative discussion of the operation and effectiveness of its liquidity risk management program. This requirement would replace the planned requirement for a firm to publicly disclose aggregate liquidity classification information about their portfolios on a quarterly basis on Form N-PORT. The SEC also proposed amendments that would change the information reported via Form N-PORT, including (i) allowing funds to report a single portfolio holding under multiple liquidity classification categories in certain circumstances and (ii) requiring registrants to report holdings of cash and cash equivalents.

If the amendments are adopted, the SEC anticipates implementing tiered compliance dates based on asset size. The SEC is requesting comments on all aspects of the proposal. Comments will be due 60 days after publication of the proposal in the Federal Register.

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