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Forum Comment Letter to the DOL on Target Date Funds

On Friday, January 14, 2011, the Forum filed its comment letter on the Department of Labor's proposed rulemaking regarding target date fund disclosures to retirement plan participants (Proposed Rulemaking: Target Date Disclosure, Rel. No. 10-1658-NAT (November 16, 2010) [75 FR 73987 (November 30, 2010)]).

Forum Comment Letter to the DOL on Target Date Funds

Forum Comment Letter on CFTC Proposal on Commodity Pool Operators

On April 12, 2011, the Forum filed its comment letter on the proposed rulemaking by the Commodity Futures Trading Commission concerning the reinstatement and expansion of commodity pool operator ("CPO") registration and reporting requirements for registered investment companies and private investment companies. (RIN Number 3038-AD30).

Forum Comment Letter to CFTC on CPO Exemption

Forum Comment Letter on the SEC Concept Release on Fund Use of Derivatives

On November 7, 2011, the Mutual Fund Directors Forums submitted its comments on the SEC's concept release "Use of Derivatives by Investment Companies under the Investment Company Act of 1940" File No. S7-33-11."

Forum Comment Letter on Fund Use of Derivatives

Forum Comment Letter on References to Credit Rating Agencies

On April 25, 2011, the Mutual Fund Directors Forums submitted its comments on the SEC's proposal, "References to Credit Ratings in Certain Investment Company Act Rules and Forms," File No. S7-07-11."

Forum Comment Letter on References to NRSROs in 2a-7

Forum Comment Letter on Potential Money Market Fund Regulations

On March 29, 2012, the Forum filed with the SEC a comment letter concerning significant money market fund reform options that the SEC is reportedly considering.

The letter makes two points, both premised on what appears to be a widely held view that if redemption restrictions or other major reforms are adopted, assets will leave money market funds. First, the draft letter emphasizes the unique role of directors in overseeing money market funds. The Forum highlights the benefits to shareholders of this governance structure, which may not be present in unregulated or off-shore cash management products. Second, the Forum's comment letter encourages the Commission to fully analyze potential systemic risk to the US financial markets of the assets currently within money market funds being moved to less regulated and/or less transparent cash management vehicles.

Forum Comment Letter on Potential Money Market Fund Reforms

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