The International Organization of Securities Commissions (IOSCO) released two detailed publications – a set of revised liquidity risk management recommendations (Report) for open-ended funds and guidance to help fund managers adopt and enforce those recommendations (Guidance) – in an effort to help curb what it sees as one of the most serious threats to the stable and orderly functioning of global private fund and financial markets, i.e., liquidity risk. The Report and Guidance are ostensibly designed to facilitate the adoption of best practices regarding liquidity. Although well-intentioned, IOSCO’s recommendations are largely principles-based and not grounded in the realities of the private funds market, legal experts told the Hedge Fund Law Report. Some of the specific recommendations overlap with existing SEC rulemaking. Others ignore critical factors that can influence fund managers’ decisions or are simply impractical in the fast-paced day-to-day world of investing and trading. This article, the second in a two-part series, delves into specific aspects of IOSCO’s liquidity management tools (LMTs) that would be highly problematic for fund managers to adopt. The first article summarized IOSCO’s revised recommendations and considered whether the SEC is likely to endorse them. For more on liquidity-related guidance and rulemaking, see “FCA Expects Hedge Fund Manages to Focus on Liquidity Risk” (Mar. 3, 2016).