SEC Seeks Extension on Fund Liquidity Info Collection Forms
Published Date: 4/10/2026
Notice
Summary
The SEC is asking to keep collecting info about how certain investment funds manage their money to make sure they can pay investors quickly. This affects open-end funds and special ETFs that trade assets instead of cash. The goal? To keep funds liquid and protect investors without adding new costs or delays.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Compliance Time and Cost Burden on Funds
The Commission estimates 12,183 funds, 705 newly-registered funds, and 3 UITs are subject to Rule 22e-4, with an internal annual burden of 16 hours per fund, 11 hours per newly-registered fund, and 8 hours per UIT, for a total annual burden of 202,699 hours. The notice estimates external costs of approximately $3,200 per fund and $2,200 per newly-registered fund and reports a total annual external cost burden of $40,536,60037.
Funds Must Run Written Liquidity Programs
Open-end funds and exchange-traded funds that redeem in kind must adopt a written liquidity risk management program with board approval and oversight. The program must include an assessment of liquidity risk with reviews no less frequently than annually, classification of portfolio investment liquidity with at-least-monthly reviews, a limit that illiquid investments may be no more than 15% of net assets, written policies on redemptions in kind, and procedures for responding to shortfalls including reporting to the fund's board.
UIT Initial Liquidity Determination Requirement
A unit investment trust's principal underwriter or depositor must determine on or before the date of the initial deposit that the portion of illiquid investments the UIT holds (that are assets) is consistent with the redeemable nature of the securities and must retain a record of that determination for the life of the UIT and for five years thereafter.
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Key Dates
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