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Forum Comment Letter on SEC's Proposal regarding Adviser Business Continuity and Transition Plans

On September 6, 2016, the Forum submitted a comment letter in response to the SEC’s proposal regarding adviser business continuity and transition plans. The Forum’s letter recognizes the importance of the issue given investors’ reliance upon a fund’s adviser’s ability to identify and manage risks related to its ability to operate continuously. However, the letter urges the Commission to consider offering staff guidance rather than specific requirements in light of the diversity represented in the adviser community.

Forum Comment Letter on SEC Investment Company Reporting Modernization Proposal

On May 24, 2016, the Forum submitted a supplemental comment letter to the SEC regarding the Commission's Investment Company Reporting Modernization rule proposal. This letter reiterated the Forum's support for proposed rule 30e-3, which would permit increased use of the Internet for funds' periodic disclosures. Read the original Forum letter on the rule here.

Forum Comment Letter on SEC Derivatives Proposal

On March 28, 2016, the Forum submitted a comment letter in response to the SEC’s derivatives proposal. The Forum’s letter recognizes “the value of adding certainty and consistency to the treatment of fund investments in derivatives under the Investment Company Act.”  While the Forum’s letter also acknowledges that boards have a role in overseeing a fund’s use of derivatives, it questions the approach taken in the proposal.

Forum Comment Letter on Transfer Agent Regulations

On April 14, 2016, the Forum submitted a comment letter in response to the SEC's concept release regarding the regulation of transfer agents. The release noted that omnibus account arrangements and increased presence of financial intermediaries have caused a reduction in transparency for fund transfer agents as to shareholder records. In its letter, the Forum urged the SEC to evaluate whether changes in its rules could provide funds and fund boards with complete information regarding the specific services performed by intermediaries and the fees for those services.

Forum Comment Letter on SEC Proposal on Liquidity Risk Management Programs, Swing Pricing

On January 13, 2015, the Forum submitted a comment letter in response to the SEC's recent rule proposals regarding the management of liquidity risk by open-end mutual funds. The Forum’s letter expresses agreement with the Commission that liquidity risk management is a fundamentally important issue and generally supports the role for directors outlined. However, the letter raises significant concerns with the prescriptive nature of requirements outlined in the proposal. 

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