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SEC Issues FAQs on Liquidity Risk Management Program Rule

Posted on January 18, 2018 at 4:20 PM

The SEC's Division of Investment Management released answers to 15 questions regarding its October 2016 liquidity risk management program rule. The SEC staff’s guidance focused on sub-advisers and In-Kind exchange-traded funds (“ETFs” - see definition in the rule).

In sum, the FAQs provide:

  • A fund may delegate specific responsibilities under a fund’s liquidity program, including serving as the program’s administrator, to a sub-adviser. 
  • ...
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