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Forum Comment Letter on SEC Investment Company Liquidity Disclosure

On May 18, 2018, the Forum submitted a comment letter in response to the Commission's rule proposals regarding Investment Company Liquidity Disclosure. In the letter, the Forum reiterates the view that liquidity risk management is an important issue for all funds and that fund boards have an important role to play in overseeing the manner in which this risk is managed, but also conveys concerns about the Commission’s approach to liquidity risk management – in particular,  concerns of the Forum membership that the recently adopted requirement that funds classify every portfolio security into a specific “liquidity bucket” will impose significant costs on funds and their shareholders without producing commensurate benefits or otherwise improving the manner in which the industry manages liquidity risk.

Forum Letter to SEC Chairman Clayton

On June 20, 2017, the Forum submitted a letter to the Chairman of the Securities and Exchange Commission discussing issues important to the independent fund directors who protect the interests of the millions of fund investors.  The letter recommends that the Commission carefully and systematically analyze and define the role it intends for directors to play.

Forum Letter to Chairman Clayton

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's Universal Proxy Rule Proposal

On February 27, 2017, the Forum submitted a comment letter in response to the Commission's rule proposals regarding the use of universal proxies in contested board elections. The Forum's letter voices support for the Commission's initial determination to exclude registered investment companies from its universal proxy proposal.

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.

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