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Swing Pricing Strikes Out Again in Recent SEC Rulemaking

September 13, 2024
Client Alert

The U.S. Securities and Exchange Commission (SEC), in a 3-2 vote, adopted amendments to fund reporting requirements on Form N-PORT and Form N-CEN and provided guidance on liquidity risk management programs (LRMPs) on August 28 (Adopting Release).1 Among other things, the amendments increase the filing and publication frequency of reporting information for funds filing on Form N-PORT and require funds filing on Form N-CEN to provide information about liquidity classification service providers.2 In connection with these amendments, the SEC did not proceed with adopting proposed changes to require mandatory swing pricing or impose a “hard close” cut-off time on when investors can buy and sell their funds (Proposing Release), consistent with comment letters from Stradley Ronon and many others on the proposal.3

 
Read the full article here.

2   For the Form N-PORT requirements, the term “fund” refers to registered open-end funds, registered closed-end funds and exchange-traded funds (ETFs) organized as unit investment trusts and excluding money market funds and small business investment companies. For the Form N-CEN requirements, the term “fund” refers to the foregoing funds with the addition of money market funds, small business investment companies and registered unit investment trusts. See Adopting Release
at 4.


Information contained in this publication should not be construed as legal advice or opinion or as a substitute for the advice of counsel. The articles by these authors may have first appeared in other publications. The content provided is for educational and informational purposes for the use of clients and others who may be interested in the subject matter. We recommend that readers seek specific advice from counsel about particular matters of interest.

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