The 16 ESMA Guidelines on Liquidity Stress Testing for UCITS and AIFs
On 2nd September 2019, the European Securities and Markets Authority (ESMA) published its final guidance regarding liquidity stress tests of investment fund…
On 2nd September 2019, the European Securities and Markets Authority (ESMA) published its final guidance regarding liquidity stress tests of investment fund…
Last week we took a brief look at the liquidity risk management regime in Hong Kong. This week, moving slightly southwest, and staying in the same continent, we review the liquidity risk requirements in Singapore. In 2018, the same year Hong Kong made amendments to its Fund Manager Code of Conduct, the Monetary Authority of Singapore (MAS) issued new Guidelines on Liquidity Risk Management Practices for Fund Management Companies (Guidelines).
Although liquidity risk management practices vary in different jurisdictions, in most cases, asset managers are required to monitor the liquidity of the fund on a frequent basis. Whilst many aspects of the regulations are broadly similar, differences can be seen from what is considered “liquid”, and around methodology to liquidity buckets, stress testing and reporting requirements. In Europe for example, neither UCITS nor AIFMD specify a specific methodology for calculating liquidity. This is in contrast to the US SEC Liquidity Risk Management Framework requirements which set out a specific methodology to be followed, although that methodology is not without its shortcomings.
This month marked one year since the collapse of Neil Woodford’s LF Woodford Equity Income fund. The Woodford fund was suspended in June, after it became overwhelmed by redemption requests from investors. One year on and investors are still awaiting their final pay-out. One year on and questions concerning the liquidity mismatches in open-ended funds still remain.
As discussed in previous blogs, later this year new FCA rules for open-ended funds investing in inherently illiquid assets enters into force. The new rules concern non-UCITS retail schemes (NURS) that invest in inherently illiquid assets. Although the new rules are relevant to anyone with an interest in open-ended investment funds that are likely to hold illiquid assets, here we will be focusing on the enhanced oversight of depositaries.
On 31 March 2020, the European Securities and Markets Authority (ESMA) announced that it was delaying the first reports by money market funds managers under the Money Market Funds Regulation (MMF Regulation) until September 2020. The original date for submissions was April 2020. The delay was due to an update to the XML schema.
Money market funds (MMFs) are an important part of the European and global investment fund landscape and perform an essential role as a cash management and liquidity tool. They are a type of collective investment fund where households, corporate treasurers or insurance companies can obtain a relatively safe and short-term investment for surplus cash. They have preservation of capital and liquidity as their primary objectives.
Fund liquidity problems witnessed in 2019 with Woodford and H2O Asset Management brought liquidity back into the spotlight. Since then, the focus hasn’t really faded on the issue of liquidity, and if anything, has intensified with the COVID-19 pandemic causing market volatility resulting in several more fund suspensions.
Although 2020 has already seen a number of initiatives intended to address liquidity risk, there are still more to come, with September due to be a particular busy month for risk management professionals.
It seems that ‘liquidity risk’ is the prevalent term on everyone’s lips these days. Following a turbulent 2019, with several high-profile fund suspensions, it is perhaps no surprise that liquidity is a 2020 priority for most regulators.
Firms must have appropriate systems, controls and governance to oversee and manage liquidity risk. With the New Year well and truly underway, regulators across the globe have started publishing their priorities for the year ahead. Unsurprisingly, liquidity risk appears to be high up on most of their agendas