Regulators have published updated guidance setting out revised expectations for liquidity risk management within open-ended fund structures, building on themes that have been developing across several jurisdictions in recent years. The guidance places particular emphasis on the alignment between a fund's stated redemption terms and the actual liquidity profile of its underlying assets.

Fund managers will need to review existing liquidity management frameworks against the updated guidance, with particular attention to stress-testing assumptions and the governance processes used to approve and monitor liquidity tools such as gates, side pockets and redemption deferrals. Managers should also expect increased scrutiny of investor disclosures relating to liquidity risk, both at the point of onboarding and on an ongoing basis.

We recommend that managers begin this review process ahead of any formal implementation deadline, given the operational lead time typically required to update liquidity management frameworks and associated investor documentation.