GARP Comments on SEC's Liquidity Risk Proposal

GARP, in consultation with its Buy?Side Risk Managers Forum Swing Pricing Sub Committee, recently responded to an SEC request for comments. The Association reviewed the SEC's proposed Liquidity Risk Management guidance and commented, specifically, on two aspects of the proposed rule: (1) the adoption of swing pricing; and (2) liquidity risk management for fund liabilities – i.e., the redeemable equity claims of individual mutual fund investors.