FYI: The SEC Division of Investment Management has issued FAQs addressing issues under the investment company LRM (Liquidity Risk Management) program rules that require funds to classify their holdings by liquidity and report their position-level liquidity classifications on Form N-PORT. Even though prior SEC action delayed the Form N-PORT reporting date for larger funds (see my FYI post dated December 8, 2017), those funds are still required to adopt liquidity programs and maintain in their records the information that is required to be included in Form N-PORT beginning no later than July 30, 2018. As such, the FAQs will be important for those funds required to adopt liquidity programs this year. The FAQs will also be important for smaller funds, when their deadlines under the liquidity program rules come into effect in coming years.
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