MFDF - Mutual Fund Directors Forum - Forum Comment Letter on SEC Investment Company Liquidity Disclosure test

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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.

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