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Investment Services and Support

State Street SEC Liquidity Rule and Reporting Modernization Solution

With mutual funds representing a key part of US savings plans, new SEC modernization regulations are looking to protect investors with more robust reporting requirements and stronger liquidity risk management requirements.

To modernize standards for data collection, reporting and disclosure practices, the SEC modernization regulations enhance the quality of information available to investors and give the SEC a better understanding of a funds’ compliance and risk exposures.

On March 1, 2017, the SEC finalized a rule that standardizes submissions in a single XML reporting format* to improve the quality and accessibility of data submitted by public companies and mutual funds. In addition to data standardization, beginning in 2017**, funds must establish a liquidity risk program that, among other things, classifies a fund’s investment holdings into categories based on settlement periods and limits a fund’s holdings in illiquid assets to no more than 15%.

To help you meet the regulatory changes, our Reporting Modernization solution performs data collection and sophisticated calculations to complete the new filings under the compressed reporting timelines. To help maintain consistency with filings, this is processed using a single source of data across reporting through our Fund Administration services.

In addition, our proprietary risk analytics engine, truView,® offers comprehensive tools to calculate risk metrics and liquidity classifications and limits, and generate reports for oversight programs. The truView results can be seamlessly integrated with our Reporting Modernization solution. Lastly, our global multi-currency accounting and custody system, supports swing pricing in the non-US jurisdictions where this is currently permissible.

* XML Filings – September 1, 2017 or September 1, 2018 for smaller reporting companies
** Regulation S-X – August 1, 2017 for enhanced disclosure reporting
** N-PORT (a monthly portfolio holdings report)
    - Fund complexes > $1 billion in net assets, first filing after June 1, 2018
    - Fund complexes < $1 billion in net assets, first filing after June 1, 2019
N-CEN (an annual census-type report): - All funds; first filing after June 1, 2018
Liquidity Rule: - Fund complexes > $1 billion in net assets, first filing after December 1, 2018
    - Fund complexes < $1 billion in net assets, first filing after June 1, 2019