SEC Extends Compliance Deadline for Certain Aspects of Liquidity Risk Management Programs Under the Investment Company Act

On February 22, 2018, the Securities and Exchange Commission (“SEC“) announced that it is adopting an interim final rule that provides a six-month extension for compliance with certain requirements of Rule 22e-4 regarding a fund’s liquidity risk management program, including the portfolio classification, highly liquid investment minimum, and board approval requirements, as well as related reporting requirements under Part D of Form N-LIQUID and liquidity disclosures on Form N-PORT under the Investment Company Act of 1940.  The interim final rule extends the compliance deadline for small entities from June 1, 2019 to December 1, 2019 and for larger entities from December 1, 2018, to June 1, 2019.  The SEC also issued guidance to assist (i) funds that will not classify their full portfolio prior to the revised compliance date and (ii) In-Kind ETFs in identifying illiquid investments for purposes of complying with the 15% illiquid investment limit under Rule 22e-4. Release.