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Matt_smith
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Matt_smithContributor
Asked: March 28, 20222022-03-28T22:50:05+00:00 2022-03-28T22:50:05+00:00In: Regulatory

Sec 22e-4 Liquidity Risk Management Program

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Should asset managers consider a security illiquid if they are in possession of material non public information on its issuer?

40 actinvestment companies actliquidity risk management programlrmp
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  1. Bobbyn Beginner
    2022-10-19T19:01:16+00:00Added an answer on October 19, 2022 at 7:01 pm

    In my opinion - Yes. If you hold mnpi on an issuer, you (without getting into unfair practice) cannot act on that mnpi which means if its negative news hitting the market, you cannot offload your holdings. Now there are multiple school of thoughts but while dealing with SEC, I try to be conservativeRead more

    In my opinion – Yes. If you hold mnpi on an issuer, you (without getting into unfair practice) cannot act on that mnpi which means if its negative news hitting the market, you cannot offload your holdings. Now there are multiple school of thoughts but while dealing with SEC, I try to be conservative as SEC is silent on these scenarios. Since each fund has to devise its own classification of Liquidity buckets, I tend to mark any sell restriction in 40 act accounts as Illiquid.

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