Eighteen Months into the Liquidity Risk Management Program Rule

May 17, 2018

ACA is pleased to present, 18 Months into the Liquidity Risk Management Program Rule, a white paper examining the points of consideration for fund complexes and their advisers that have surfaced in the eighteen months since the rule took effect.

A Synopsis: Back to the Future

Around this time last year, we began to explore the Securities and Exchange Commission’s (the “Commission”) investment company liquidity risk management program rule (the “liquidity program rule”).1 Specifically, we looked at some of the liquidity program rule’s more regularly discussed requirements, the ones viewed by some as implementation “pain points.” A year later, these requirements still dominate the implementation discussion. Fortunately, with age comes wisdom, accompanied in this case by Commission staff guidance, compliance date delays, and proposed rule amendments.

The past 12 months and especially the last four have been an interesting ride. This white paper revisits many of the same areas as last year from the perspective of what we know now. It also looks ahead a bit. So, for all you 1980s film buffs, get inside the DeLorean as we generate 1.21 gigawatts and travel back to the future.

Discover what we’ve learned so far and what to keep in mind for the coming months.

Download your complimentary white paper here.

Additional Liquidity Risk Management Program Resources

Visit ACA’s Liquidity Risk Management Program Rule resource page for access to white papers, news insights, and webcasts to assist funds, ETFs, advisers, and sub-advisers in understanding the intricacies and requirements of the liquidity risk management program rule.

For more information about the Liquidity Risk Management Program Rule or any of our Investment Company Services, please contact Maureen Colligan at (617) 589-0904 or mcolligan@acacompliancegroup.com.