Image
Resource Hub
Liquidity Risk Management Program Rule
This resource center is designed to assist members in understanding, implementing, and administering these requirements. It also highlights our related policy work.
Overview
Mutual funds (excluding money market funds) and ETFs are subject to a comprehensive liquidity risk management regulatory framework, adopted by the SEC in 2016 and amended in 2018. In 2024, the SEC provided additional guidance to funds about their liquidity risk management program requirements. The SEC’s 2022 proposal would (i) amend the liquidity risk management rule for mutual funds and ETFs and (ii) mandate that mutual funds impose a “hard close” on investors’ orders and use swing pricing.
ICI Contacts
News & Publications
News & Publications
ICI Commentary: What the Bank of England’s System-Wide Exploratory Scenario Exercise (SWES) Tells Us
February 19, 2025—In late November 2024, the Bank of England published the results of its first system-wide exploratory scenario (SWES) exercise—a year-long effort to model how various financial entities, including non-bank financial intermediaries (NBFIs) and banks, would respond to a significant liquidity shock.
ICI Statement on SEC Adoption of New N-PORT Reporting and Liquidity Risk Management Guidance
August 28, 2024—ICI President and CEO Eric Pan released a statement regarding the Securities and Exchange Commission’s vote to adopt changes to Form N-PORT reporting requirements and liquidity risk management program guidance.
The SEC’s Liquidity Proposal Is Arbitrary and Harmful to Investors
January 12, 2024—Open-end long-term mutual funds (“funds”) have a long history of successfully managing liquidity, enabling them to meet shareholder redemptions in a timely manner while pursuing their investment objectives. Over the past four decades, 99.94% of these funds have met redemptions, including every single fund during the 2008 global financial crisis and the 2020 dash for cash.
ICI Global Welcomes FSB and IOSCO Reports on Liquidity Risk Management for Open-Ended Funds
December 20, 2023—ICI Global welcomed the Financial Stability Board (FSB) and the International Organization of Securities Commissions’ (IOSCO) final reports on open-end fund liquidity risk management.
Research & Statistics
Research & Statistics
ICI Response to IOSCO Consultations on OEF Liquidity Risk Management
February 11, 2025—ICI submitted a letter in response to the International Organization of Securities Commission’s consultation on revised recommendations for liquidity risk management for open-end funds.
ICI Response to ESMA Liquidity Management Tools Consultation
October 8, 2024—ICI filed a response to the European Securities and Markets Authority’s consultations regarding draft regulatory technical standards and guidelines on liquidity management tools.
ICI Global Response to the FSB's Consultation on Liquidity Preparedness
ICI Global provided comments on the Financial Stability Board’s consultation on Liquidity Preparedness for Margin and Collateral Calls.
Additional Resources
Resources
Background
- Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management Programs (August 28, 2024)
- SEC’s 2022 Liquidity, Swing Pricing, Hard Close, and Form N-PORT proposal (November 2, 2022)
- SEC Liquidity Disclosure Amendments (pdf) (June 28, 2018)
- SEC Staff Frequently Asked Questions: Investment Company Liquidity Risk Management Programs (Feb 22, 2018)
- SEC Interim Final Rule on Investment Company Liquidity Risk Management Programs (Feb 22, 2018)
- SEC Final Rule on Investment Company Liquidity Risk Management Programs (Adopting Release) (Oct 13, 2016)
Global Initiatives
- IOSCO’s Anti-dilution Liquidity Management Tools – Guidance for Effective Implementation of the Recommendations for Liquidity Risk Management for Collective Investment Schemes (pdf) (Dec, 2023)
- FSB’s Revised Policy Recommendations to Address Structural Vulnerabilities from Liquidity Mismatch in Open-Ended Funds (pdf) (Dec, 2023)
- IOSCO’s Open-ended Fund Liquidity and Risk Management – Good Practices and Issues for Consideration (pdf) (Feb, 2018)
- IOSCO’s Recommendations for Liquidity Risk Management for Collective Investment Schemes (pdf) (Feb, 2018)