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ARTICLE · 10 SEPTEMBER 2024

SEC Issues Guidance On Fund Liquidity Risk Management Programs And Amends Forms N-PORT And N-CEN

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On August 28, 2024, the SEC published a release (the "Release") containing guidance based on the SEC staff's monitoring of funds' liquidity classifications and liquidity risk...

United StatesWealth Management
Ropes & Gray LLP
Ropes & Gray LLP
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On August 28, 2024, the SEC published a release (the "Release") containing guidance based on the SEC staff's monitoring of funds' liquidity classifications and liquidity risk management programs mandated by Rule 22e-4 under the 1940 Act (the "Guidance"). The Guidance covers issues concerning:

  • How frequently a fund should review the liquidity classifications of its investments;
  • The meaning of the term "cash" under Rule 22e-4, which excludes foreign currencies, and the implications of this exclusion; and
  • Relevant considerations when determining a fund's highly liquid investment minimum ("HLIM").

The Release also adopts amendments to Forms N-PORT and N-CEN (the "Amendments") that are consistent with the amendments proposed in the SEC's now-postponed 2022 proposals to overhaul open-end fund liquidity risk management programs and to implement mandatory swing pricing for all open-end funds, except money market funds (the "2022 Release").1

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