During a recent webinar, Steve explained that the market and trading conditions caused by the COVID-19 pandemic might be “reasonably expected to materially affect one or more of [a mutual fund’s] investments’ classifications” for purposes of the fund’s liquidity risk management program (its “LRM Program”). In this circumstance, Rule 22e-4 under the Investment Company Act of 1940 requires more frequent review of these classifications. This post describes how a rough market may require a mutual fund (other than a money market fund or in-kind exchange traded fund) to reclassify an investment’s liquidity classification.
Continue Reading Navigating Mutual Funds in Rough Markets—Liquidity
22(e)
Revised Money Market Reform FAQs—Why Gating Would Be an Emergency
By Stephen A. Keen on
Posted in Compliance, Money Market Funds
This is the second installment of my review of the update to the 2014 Money Market Fund Reform Frequently Asked Questions (the “FAQs”) released on August 4th. This post will explain a new FAQ that addresses whether gating a fund represents an “emergency.”…
Continue Reading Revised Money Market Reform FAQs—Why Gating Would Be an Emergency