Registered Investment Company Update

New guidance on liquidity risk management programs

KENNETH S. GERSTEIN, JOHN J. MAHON, KAREN SPIEGEL AND JESSICA A. FALZONE, SCHULTE ROTH & ZABEL

On Jan. 10, 2018, the staff of the Division of Investment Management of the SEC posted responses to a number of Frequently Asked Questions (“Staff FAQs”) concerning liquidity risk management (“LRM”) programs required to be implemented pursuant to new Rule 22e-4 under the Investment Company Act of 1940 (“1940 Act”).1 Under Rule 22e-4, adopted by the SEC in October 2016,2 1940 Act registered...

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