October 21, 2016

SEC Adopts Liquidity Risk Management Program Requirements

The Securities and Exchange Commission (the "SEC") voted recently to adopt new Rule 22e-4 under the Investment Company Act of 1940, as amended (the "1940 Act"), (the "Rule")1 that will require registered open-end management investment companies, including mutual funds and exchange-traded funds ("ETFs")2 (each a "fund") (but excluding money market funds), to adopt and implement written liquidity risk management programs designed to assess and manage liquidity risk.3

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October 13, 2016

SEC Proposes Rule Amendment to Expedite Securities Transaction Settlement Process

The Securities and Exchange Commission (“SEC”) recently proposed an amendment to Rule 15c6-1(a) under the Securities Exchange Act of 1934 (“Exchange Act”) to shorten the standard settlement cycle for most broker-dealer securities transactions from three business days after the trade date (“T+3”) to two business days after the trade date (“T+2”). The proposed amendment would prohibit a broker-dealer from entering into a contract for the purchase or sale of a security (other than an exempted security, government security, municipal security, commercial paper, bankers’ acceptances, or commercial bills) that provides for payment of funds and delivery of securities later than two business days after the trade date, unless otherwise expressly agreed to by the parties at the time of the transaction.

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