Registered Funds Alert, November 2016
This latest edition of Simpson Thacher’s Registered Funds Alert discusses: the SEC’s final rules regarding liquidity risk management and data reporting and notable changes since the rules were initially proposed; the potential for recent money market reforms to affect how corporate treasurers handle cash reserves and potential traps that could trigger 1940 Act registration requirements; and a summary of what happened when a fund board discovered that the funds’ adviser may have provided false or misleading information during the Section 15(c) contract approval process.