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Stay up to date with upcoming final rule compliance dates, and pending rule proposals.
Updated As-Of March 2024
| Rule | Description | Date Adopted | Compliance Date |
|---|---|---|---|
| Climate Change Disclosure | The final rule calls for companies to include certain climate-related disclosures in their registration statements and periodic reports, including information about climate-related risks that are reasonably likely to have a material impact on their business. The rule also would require disclosure of climate-related metrics, including greenhouse gas emissions (Scope 1 and 2). | March 7, 2024 | Phased in for all registrants, with the compliance date dependent on the registrant’s filer status. |
| Enhanced Proxy Vote Reporting (Form N-PX) | Registered funds must disclose more details about their proxy votes. The rule requires funds to disclose how many shares of a public company that Enhanced Proxy Votes they hold, as well as how each share voted on each proxy proposal (including shares on loan). Funds also need to label each proxy proposal they voted on using categories provided by regulators, in a required order. | November 2, 2022 | August 31, 2024 |
| Registered funds must disclose more details about their proxy votes. The rule requires funds to disclose how many shares of a public company that Enhanced Proxy Votes they hold, as well as how each share voted on each proxy proposal (including shares on loan). Funds also need to label each proxy proposal they voted on using categories provided by regulators, in a required order. | |||
| Tailored Shareholder Reports | Mutual funds and ETFs are required to prepare and transmit streamlined annual and semiannual shareholder reports. The new reports must be sent directly to Investors, either on paper or electronically for those who have consented to e-delivery. And the reports must be structured in a machine-readable format. Details must be filed on Form N-CSR, posted online and delivered upon request. | October 26, 2022 | July 24, 2024 (Applies to reports with FYE on or after May 24, 2024) |
| Mutual funds and ETFs are required to prepare and transmit streamlined annual and semiannual shareholder reports. The new reports must be sent directly to Investors, either on paper or electronically for those who have consented to e-delivery. And the reports must be structured in a machine-readable format. Details must be filed on Form N-CSR, posted online and delivered upon request. | |||
| Reporting of Securities Loans | Asset Managers and other market participants are now required to report the terms of securities loans to FINRA by the end of the day of effecting or modifying loans. | October 13, 2023 | January 2, 2026 |
| Registered funds must disclose more details about their proxy votes. The rule requires funds to disclose how many shares of a public company that Enhanced Proxy Votes they hold, as well as how each share voted on each proxy proposal (including shares on loan). Funds also need to label each proxy proposal they voted on using categories provided by regulators, in a required order. | |||
| Names Rule | The amendments to Rule 35d-1 require more funds to adopt a policy to invest at least 80% of the value of their assets in accordance with the investment focus that the fund name suggest. The new rules cover products with name that allude to growth, value, income and environmental, governance and social strategies. The update also calls for terminology used in fund names to be defined in the prospectus. | September 20, 2023 | December 11, 2025 (for funds with net assets of $1B or more. And June 11, 2026 for funds with less than $1B) |
| The amendments to Rule 35d-1 require more funds to adopt a policy to invest at least 80% of the value of their assets in accordance with the investment focus that the fund name suggest. The new rules cover products with name that allude to growth, value, income and environmental, governance and social strategies. The update also calls for terminology used in fund names to be defined in the prospectus. | |||
| Money Market Fund Reforms | The amendments will increase minimum liquidity requirements for money market funds. The changes remove provisions that permit money funds to suspend redemptions temporarily through a gate. For prime and tax-exempt funds, a mandatory liquidity fee must be imposed when the funds face redemptions greater than 5% of their assets. non-government money market funds must impose a discretionary liquidity fee if the fund’s board (or its delegate) determines that a fee is in the best interest of the fund. | July 12, 2023 | The reporting form amendments will become effective June 11, 2024; Six-month transition period for funds to comply with certain amendments, including the minimum portfolio liquidity requirements and the discretionary liquidity fee provision; 12 months after effective date to comply with mandatory liquidity fee provision (October 2, 2024). |
| The amendments will increase minimum liquidity requirements for money market funds. The changes remove provisions that permit money funds to suspend redemptions temporarily through a gate. For prime and tax-exempt funds, a mandatory liquidity fee must be imposed when the funds face redemptions greater than 5% of their assets. non-government money market funds must impose a discretionary liquidity fee if the fund’s board (or its delegate) determines that a fee is in the best interest of the fund. | |||
| Share Repurchase Disclosure Modernization | Listed closed-end funds are required starting next year to disclose more information about repurchased shares. Semiannually closed funds must report the class of shares --- repurchased; the average price paid per share; the total number purchased, including the amount bought through the open market; and the aggregate maximum of share that may be repurchased under announced plan policies. The information must be disclosed in a tabular format and show the daily breakdown of repurchased activity. | May 3, 2023 | Delayed (Pending further SEC Commissioner action due to 5th Circuit Court Order) |
| Listed closed-end funds are required starting next year to disclose more information about repurchased shares. Semiannually closed funds must report the class of shares --- repurchased; the average price paid per share; the total number purchased, including the amount bought through the open market; and the aggregate maximum of share that may be repurchased under announced plan policies. The information must be disclosed in a tabular format and show the daily breakdown of repurchased activity. | |||
| T+1 Settlement | Regulators shortened the standard settlement cycle for most securities transactions from two business days after the trade date to one, moving from T+2 to T+1. | Feb 15, 2023 | May 28, 2024 |
| Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews | The rules require private fund advisers registered with the Commission to: Provide investors with quarterly statements detailing information regarding private fund performance, fees, and expenses; Obtain an annual audit for each private fund; and Obtain a fairness opinion or valuation opinion in connection with an adviser-led secondary transaction. The new rules require that all private fund advisers: Prohibit engaging in certain activities and practices that are contrary to the public interest and the protection of investors unless they provide certain disclosures to investors, and in some cases, receive investor consent; and Prohibit providing certain types of preferential treatment that have a material negative effect on other investors and prohibit other types of preferential treatment unless disclosed to current and prospective investors. Additionally, the amendments will require all registered advisers, including those that do not advise private funds, to document in writing the annual review of their compliance policies and procedures. | August 23, 2023 | For the Private Fund Audit Rule and the Quarterly Statement Rule, the compliance date will be March 14, 2025. For the Adviser-Led Secondaries Rule, the Preferential Treatment Rule, and the Restricted Activities Rule, the compliance dates are: for advisers with $1.5 billion or more in private funds assets under management, September 14, 2024; and for advisers with less than $1.5 billion in private funds assets under management, March 14, 2025. Compliance with the amended Advisers Act compliance rule was November 14, 2023. |
| Regulators shortened the standard settlement cycle for most securities transactions from two business days after the trade date to one, moving from T+2 to T+1. | |||
Updated as-of March 2024
| Rule | Description | Date Proposed | Status |
|---|---|---|---|
| Predictive Analytics (“AI Rule”) | The proposal would require broker-dealers and investment advisors to evaluate any use of technology that “optimize for, predict, guide, forecast or direct investment-related behaviors or outcomes of an investor.” Firms would have to determine whether any of these tools place their interests ahead of investors. Written policies and procedures would be required to achieve compliance, and any identified conflicts of interest would need to be eliminated or neutralized. | July 26, 2023 | Comment Period: Closed on Oct 10, 2023 Reg Flex Agenda: Final Action for April 2024 |
| The proposal would require broker-dealers and investment advisors to evaluate any use of technology that “optimize for, predict, guide, forecast or direct investment-related behaviors or outcomes of an investor.” Firms would have to determine whether any of these tools place their interests ahead of investors. Written policies and procedures would be required to achieve compliance, and any identified conflicts of interest would need to be eliminated or neutralized. | |||
| Safeguarding Advisory Client Assets (“Custody Rule”) | The proposal would expand the scope of the current custody rule beyond client funds and securities to include any client assets of which an advisor has custody. Digital assets and cryptocurrencies would fall under the scope of the new rule. Advisors with custody of client assets must maintain those assets with a qualified custodian, such as a registered broker-dealer or state-charted bank. Advisors must have a written agreement with qualified custodians with assurances that clients receive certain standard custodial protections when an advisor has custody of their assets. | Feb 15, 2023 | Comment Period: Closed on Oct 30, 2023 Reg Flex Agenda: Final Action for April 2024 |
| The proposal would expand the scope of the current custody rule beyond client funds and securities to include any client assets of which an advisor has custody. Digital assets and cryptocurrencies would fall under the scope of the new rule. Advisors with custody of client assets must maintain those assets with a qualified custodian, such as a registered broker-dealer or state-charted bank. Advisors must have a written agreement with qualified custodians with assurances that clients receive certain standard custodial protections when an advisor has custody of their assets. | |||
| Best Execution | The SEC proposal would require broker-dealers to establish, maintain and enforce written policies and procedures that detail how they will determine the best market for securities and make routing for execution decisions for customer orders. The “execution quality” of customers’ transactions would need to be reviewed at least quarterly and P&Ps would need to be reviewed at least annually. | Dec 14, 2022 | Comment Period: Closed on Mar 31, 2023 Reg Flex Agenda: Final Action for April 2024 |
| The SEC proposal would require broker-dealers to establish, maintain and enforce written policies and procedures that detail how they will determine the best market for securities and make routing for execution decisions for customer orders. The “execution quality” of customers’ transactions would need to be reviewed at least quarterly and P&Ps would need to be reviewed at least annually. | |||
| Liquidity Risk Mgmt./Swing Pricing/4pm Hard Close | The proposal would require funds to update liquidity risk management programs, including liquidity classifications. The proposal also would require funds, other than mm funds, to implement swing pricing to adjust a fund’s NAV per share to pass on costs stemming from shareholder purchase or redemption activity to the shareholders engaged in that activity. The swing pricing requirement would necessitate the Implementation of a "hard close" for the funds where shares could be redeemed or purchased at the current day's price only if the fund, its designated transfer agent receives the order before the pricing time as of which the fund calculates its NAV (typically 4 pm). | Nov 2, 2022 | Comment Period: Closed on Feb 14, 2023 Reg Flex Agenda: Final Action for April 2024 |
| The proposal would require funds to update liquidity risk management programs, including liquidity classifications. The proposal also would require funds, other than mm funds, to implement swing pricing to adjust a fund’s NAV per share to pass on costs stemming from shareholder purchase or redemption activity to the shareholders engaged in that activity. The swing pricing requirement would necessitate the Implementation of a "hard close" for the funds where shares could be redeemed or purchased at the current day's price only if the fund, its designated transfer agent receives the order before the pricing time as of which the fund calculates its NAV (typically 4 pm). | |||
| Outsourcing By Investment Advisors | The proposed rule would require advisors to conduct due diligence prior to engaging a service provider to perform certain services or functions as well as to periodically monitor their performance and reassess their retention. Functions listed include compliance duties and those that, if negligently performed, could cause a material negative impact on the advisor’s clients or its ability to provide investment advisory services. Clerical, ministerial, utility and general office functions or services are explicitly excluded under the proposal. The agency may also move to collect “census-type information” about the providers covered. | Oct 26, 2022 | Comment Period: Closed on December 27, 2022 Reg Flex Agenda: Final Action by April 2024 |
| The proposed rule would require advisors to conduct due diligence prior to engaging a service provider to perform certain services or functions as well as to periodically monitor their performance and reassess their retention. Functions listed include compliance duties and those that, if negligently performed, could cause a material negative impact on the advisor’s clients or its ability to provide investment advisory services. Clerical, ministerial, utility and general office functions or services are explicitly excluded under the proposal. The agency may also move to collect “census-type information” about the providers covered. | |||
| Enhanced ESG Investment Practices Disclosures | The proposal required funds that consider ESG factors In their Investment process to disclose additional information regarding their strategy. The proposal also would require categorizing the strategies as “integration”, “ESG-focused”, or “impact funds”, with associated disclosures. | May 25, 2022 | Comment Period: Closed on June 17, 2022 (re-opened for additional 14 days) Reg Flex Agenda: Final Action by April 2024 |
| The proposal required funds that consider ESG factors In their Investment process to disclose additional information regarding their strategy. The proposal also would require categorizing the strategies as “integration”, “ESG-focused”, or “impact funds”, with associated disclosures. | |||
| The proposal calls for companies to include certain climate-related disclosures in their registration statements and periodic reports, including information about climate-related risks that are reasonably likely to have a material impact on their business. The proposal also would require disclosure of climate-related metrics, including greenhouse gas emissions. | |||
| Listed closed-end funds are required starting next year to disclose more information about repurchased shares. Semiannually closed funds must report the class of shares --- repurchased; the average price paid per share; the total number purchased, including the amount bought through the open market; and the aggregate maximum of share that may be repurchased under announced plan policies. The information must be disclosed in a tabular format and show the daily breakdown of repurchased activity. | |||
| Cybersecurity Risk Mgmt. for Funds | The proposed cybersecurity risk management rules would require advisors and fund to implement policies and procedures designed to address cybersecurity risks. Regulators have also recommended significant cybersecurity incidents be required to be disclosed to the SEC confidentially within 48 hours of determining such an incident has occurred. Funds would be required to provide a description of any significant fund cybersecurity incidents that have occurred in the past two fiscal years in their registration statements. | Feb 9, 2022 | Comment Period: Closed on April 11, 2022 Reg Flex Agenda: Final Action by April 2024 |
| The proposed cybersecurity risk management rules would require advisors and fund to implement policies and procedures designed to address cybersecurity risks. Regulators have also recommended significant cybersecurity incidents be required to be disclosed to the SEC confidentially within 48 hours of determining such an incident has occurred. Funds would be required to provide a description of any significant fund cybersecurity incidents that have occurred in the past two fiscal years in their registration statements. | |||
The SEC is required, twice each year, to publish significant rules they are considering in the next 12 months. This agenda doesn't limit their consideration or action on other matters, nor does it require them to act on listed matters. The SEC retains the flexibility to address items sooner or later than indicated. While the agenda outlines intentions for rulemaking in the coming year, specific dates aren't guaranteed. Items without estimated dates are categorized as long-term, but the SEC may still act on them within the year.
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| Table Heading | |
|---|---|
| +1 800 353 0103 | North America |
| +442075513000 | EMEA |
| +65 6438 1144 | APAC |
Your sales rep submission has been received. One of our sales representatives will contact you soon.
Want to speak with a sales representative?
| Table Heading | |
|---|---|
| +1 800 353 0103 | North America |
| +442075513000 | EMEA |
| +65 6438 1144 | APAC |