Fund website regulatory requirements
Open questions for counsel
Interpretations the build depends on. Record counsel's answer in the note when confirming each one.
One pending SEC proposal touches fund websites: Regulation E-Delivery, proposed July 16, 2026, with comments closed September 21, 2026. It would make electronic delivery the default and rescind Rule 30e-3. As a proposal, nothing in it should be built yet (FilePoint).
Does counsel agree the Rule 498 and 30e-1 outage safe harbors cover a period served by a complete failover site, and that no such harbor exists for Rule 6c-11 and 2a-7 data?
ETF-02: confirm the source and wording for listing foreign currency by specific currency.
MF-05: confirm supplements must sit next to the prospectus they amend.
MMF-06: is any website posting required for liquidity fee or liquidity threshold events under the 2023 reforms?
MMF daily data: is there an intraday cutoff, or is "each business day" enough?
REC-01: which URLs are printed in ads and fact sheets for month-end performance?
Which funds use exemptive orders (semi-transparent ETFs) rather than Rule 6c-11, and what do those orders require on the website?
How long must the evidence log and failover activation history be kept?