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A Look Back In Time: Analyzing The Success And Value Of The 2014 Amendments To Rule 2a-7 And Reporting On Form N-Cr In Light Of The March 2020 Market Events, Jocelyn Near
Catholic University Law Review
Money market funds have frequently been a target of regulation by the Securities and Exchange Commission (“SEC”). Perhaps the most expansive regulation came as a response to the 2008 financial crisis, in which the Reserve Primary Fund “broke the buck.” The SEC’s misguided 2014 reforms exacerbated the inherent risks of money market funds, including the risk of runs and first mover advantage, particularly with the implementation of Form N-CR. Form N-CR requires a money market fund to publicly report when various events occur, including when a retail or government money market fund’s current net asset value per share deviates downward …
Can The Liquidity Rule Keep Mutual Funds Afloat? Contextualizing The Collapse Of Third Avenue Management Focused Credit Fund, Nicolas Valderrama
Can The Liquidity Rule Keep Mutual Funds Afloat? Contextualizing The Collapse Of Third Avenue Management Focused Credit Fund, Nicolas Valderrama
Catholic University Law Review
In 2016, the Securities and Exchange Commission adopted Rule 22e-4 (the “Liquidity Rule”) under the Investment Company Act of 1940, as amended, and related reporting and disclosure requirements. One industry analyst described the Liquidity Rule’s objective as making sure that mutual funds implement “effective liquidity risk management programs,” especially in light of mutual funds’ prevalence in the economy and in American households. Yet, as one Reuters analyst suggested, the SEC also seemed to have adopted these liquidity regulations, to avoid a “repeat of the kind of problems that surfaced with the collapse of the [mutual fund] Third Avenue Focused Credit …