MFDF - Mutual Fund Directors Forum - Forum Comment Letter on SEC Proposal on Liquidity Risk Management Programs, Swing Pricing test

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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.