REGULATION

Money Market Funds Stress-Testing Changes Imminent

The 2016 compliance dates for new rules included in the SEC's money market fund reforms are fast approaching. Among other things, the reforms include changes to stress-testing requirements, disclosure requirements, net asset value (NAV) calculations, and minimum liquidity thresholds.

In a recently published article, Money Market Mutual Funds: Stress Testing and the New Regulatory Requirements, professionals from NERA Economic Consulting offer practical insights into the implementation of the new stress-testing requirements.

The complete article is available here. For additional information, visit our BD/IA Regulator blog post here.

SEC Solicits Comments on Exchange-Traded Products

Citing significant growth in the size and scope of exchange-traded products (ETPs), on June 12, 2015, the SEC solicited comments to assist the staff's review of listing and trading "new, novel, or complex ETPs, including requests by ETPs for exemptive and no-action relief. . . ." While the SEC acknowledges its extensive experience with ETPs, it believes that engaging with the broader public and investment community will be beneficial to its continued oversight.

Of particular interest to the SEC are comments with respect to its oversight of ETPs under the Securities Exchange Act of 1934 ("Exchange Act"), including:

  • views on the listing and trading of ETPs;
  • the manner in which ETPs trade in the secondary market; and
  • exemptive or no-action relief granted to ETPs under the Exchange Act.

The SEC is also interested in receiving comments on how broker-dealers:

  • recommend and sell ETPs to investors; and
  • fulfill their obligations to investors when recommending and selling ETPs, in light of FINRA's existing guidance regarding complex products and ETPs.

For additional information, visit our BD/IA Regulator blog post here. Comments are due by August 17, 2015.

To read this update in full, please click here.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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