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2020 Liquidity Risk Management Program

Survey Results

To continue providing the fund industry with transparency and insight into how peers are approaching compliance with the liquidity program rule, ACA released a survey in June, 2020 on the heels of the March and April U.S. market turbulence stemming from the COVID-19 pandemic. This white paper discusses the results of that survey.

December 1, 2019 represents the last of four compliance dates for the Securities and Exchange Commission’s liquidity risk management program rule. Larger fund groups saw their first milestones pass in December 2018 and June 2019. Meanwhile, smaller fund groups saw their compliance milestones pass in June and December 2019. With that, this third annual ACA survey of mutual funds/ETF complexes and investment advisers and sub-advisers to mutual funds/ETFs is the first to capture full liquidity program rule compliance for the fund industry.

This year's survey covered the following topics:

  • Liquidity Program Administrator
  • Liquidity Classification
  • Asset Classification
  • Highly Liquid Investment Minimun vs. Primarily Highly Liquid Investments
  • Compliance Warning Tolerances
  • Liquidity Risk
  • Liquidity Sources
  • Board Reporting