US Corporate Law News: SEC proposes amendments to public liquidity risk management disclosure

On March 14, 2018, the SEC proposed amendments to its public liquidity-related disclosure requirements (adopted in October 2016) for certain open-end investment management companies to establish a written liquidity risk management program. As part of the initial 2016 program, funds were required to (a) confidentially submit monthly position-level data to the SEC and (b) publicly disclose quarterly aggregate liquidity data by classifying securities (referred to as the “bucket approach”). The SEC's proposed amendments would replace the bucket approach and instead require funds to discuss the operation and effectiveness of their liquidity risk management programs in their annual reports. The proposed rules represent a continuation of the SEC's efforts to promote effective liquidity risk management programs in the fund industry. The SEC is aiming to provide investors with context to better understand how securities classifications relate to fund liquidity and risk management, so as to better inform investors of how fund liquidity risk (and liquidity risk management) may affect investments. For more information, see