The SEC published its final investment-company liquidity rule on November 18, 2016. Its general effective date is January 17, 2017, with an exception for Form N-CEN amendments, which take effect June 1, 2018. Neither date should be read as a single deadline for every fund program and disclosure change contained in the instrument. [2016-25348]

Section III.M separately sets liquidity-program compliance for December 1, 2018 for larger entities and June 1, 2019 for smaller entities. It gives Form N-1A amendments a June 1, 2017 compliance date. These are different obligations on different clocks. A statement that all the new liquidity duties begin in January 2017 would collapse distinctions the SEC expressly retained. [2016-25348]

The program rule concerns registered open-end management investment companies, including open-end ETFs, rather than every investment vehicle. Money-market funds are excluded from the program requirement, although certain form amendments apply to them. Qualifying In-Kind ETFs have exceptions from liquidity classification and the highly liquid investment minimum, so the broad fund label does not establish identical treatment. [2016-25348]

The October 2015 proposal described a proposed three-day liquid-asset minimum alongside an illiquid-asset limit. It explains the development of the policy, not the final wording of every duty. Proposal and final rule are linked primary documents from one regulator, not independent outcome studies. They establish a regulatory design and its timetable; they do not establish that redemption failures or dilution have already declined. [2016-25348][2015-24507]

Source documents

  1. Investment Company Liquidity Risk Management Programshttps://www.govinfo.gov/content/pkg/FR-2016-11-18/html/2016-25348.htm
  2. Open-End Fund Liquidity Risk Management Programs; Swing Pricing; Re-Opening of Comment Period for Investment Company Reporting Modernization Releasehttps://www.govinfo.gov/content/pkg/FR-2015-10-15/html/2015-24507.htm