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IOSCO Reviews Implementation of Liquidity Risk Management Recommendations

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IOSCO/MR/35/2022 – Madrid, 16 November 2022

IOSCO today published a thematic review (‘Review’) assessing the implementation of selected recommendations (‘Recommendations’) issued in 2018 to strengthen the liquidity risk management practices for collective investment schemes (‘CIS’) globally.

Jean Paul Servais, IOSCO Board Chairman and Chairman of the Belgium FSMA, said “Effective liquidity management is crucial to safeguard the interests of investors, to maintain the orderliness and robustness of collective investment schemes and markets, and to reduce systemic risks. Effective liquidity management therefore contributes to financial stability. IOSCO will continue to engage with the industry, its members, and other international bodies to ensure that sound liquidity management practices are implemented.

The Review found that larger jurisdictions show a high degree of implementation of regulatory requirements consistent with the objectives of the Recommendations. For the CIS design process, the Review identified some challenges with respect to dealing frequency, dealing arrangements and disclosure practices. For day-to-day liquidity management, the Review found that some jurisdictions may need to improve the process of identification of a liquidity shortage before it occurs and provide more guidance on aligning the investment strategy, liquidity profile and redemption policy. Other related areas that may warrant further attention include data availability and third-party providers of liquidity metrics. With regards to contingency planning, the Review found that jurisdictions should further address the availability of liquidity management tools and supplement the current rules and regulations to include requirements that are more specific regarding the use of such tools.

Additionally, the Review found that responsible entities (i.e., asset managers) have a high degree of implementation of the Recommendations at the level of policies and practices. While all large global responsible entities described practices that were consistent with the Recommendations, improvement might be needed by smaller and less-resourced entities with regard to their liquidity disclosure provisions in their CIS design process. Some weaknesses were also identified in operationalizing contingency plans and activation of liquidity risk management tools.

Sharon Kelly, Chair of the IOSCO Assessment Committee and Senior Analyst, Quebec AMF, said, “The work of the Assessment Committee is critical to IOSCO and its members. Unless implemented, issuing international standards remains ineffective. The findings from the Review indicate that IOSCO’s Recommendations in this area are broadly well implemented. We nevertheless call on both jurisdictions and responsible entities to address the remaining shortcomings identified in our report.

The findings from this Review have informed the FSB’s assessment of the effectiveness of the FSB’s 2017 policy recommendations to address structural vulnerabilities from liquidity mismatch in open ended funds.

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