In a March 27 BoardIQ article titled , “Should Boards OK Liquidity Program Before Deadline?,” investment management partners Paulita Pike and Greg Sheehan discuss the “awkward position” fund boards are in arising from the SEC’s new liquidity rule deadline, whereby advisers must have a liquidity risk management program in place by December, while boards do not have to approve it until the following June. “The idea that the fund has to have something in place that would be done without board approval does create a gap in terms of what the advisers’ expectations might be and what the boards’ expectations might be,” states Ms. Pike. “Boards must ultimately sign off on the plan, so some directors may want to thoroughly assess the proposal now to make sure they agree with it or because they believe that doing so is in accord with the business judgment rule,” states Mr. Sheehan.
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