MFDF - Mutual Fund Directors Forum - Comment Letters test

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Forum Comment Letter on Securities Offering Reform for CEF

On June 12, 2019, the Forum submitted a comment letter in response to the SEC’s rule proposal regarding securities offering reform for closed end investment companies.

 

Forum Comment Letter on Fund-of-Funds Proposal

On May 2, 2019, the Forum submitted a comment letter in response to the SEC’s proposal to govern fund-of-funds relationships by rule rather than through the exemptive process.

 

Forum Comment Letter on SEC's Loan Rule Proposal

On July 9, 2018, the Forum submitted a comment letter in response to the Commission's rule proposals regarding Auditor Independence with Respect to Certain Loans or Debtor-Creditor Relationships. In the letter, the Forum supporting the Commission's revised approach to auditor independence with respect to the loan provision. 

Forum Comment Letter on ETF Proposal

On October 1, 2018, the Forum submitted a comment letter in response to the Commission's rule proposal permitting ETFs that satisfy certain conditions to operate without the expense or delay of obtaining an exemptive order. 

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.

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