IOSCO Revises Liquidity Management Recommendations for Private Funds (Part One of Two)

On June 26, 2025, the International Organization of Securities Commissions (IOSCO) released a report, “Revised Recommendations for Liquidity Risk Management for Collective Investment Schemes” (Report), presenting revisions of its 2018 publication on the same subject. IOSCO also issued a separate guidance document (Guidance), which supplements the Report and provides practical suggestions to help fund managers make sense of and adopt the more technical revised recommendations. In the Report, IOSCO is candid about the fact that it expects securities regulators to promote the implementation of its revised recommendations aggressively. However, although both new publications address material issues facing fund managers, legal experts interviewed by the Hedge Fund Law Report expressed skepticism about whether IOSCO’s recommendations are in line with the realities of the private funds market and will be favorably received in the United States and elsewhere. This article, the first in a two-part series, summarizes IOSCO’s revised recommendations and considers whether the SEC is likely to endorse them. The second article will delve into specific aspects of IOSCO’s proposed liquidity management tools, as set forth in the Guidance, that would be highly problematic for fund managers to adopt. See “IOSCO Issues Seven Key Outsourcing Principles” (Dec. 16, 2021).

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