Mar. 8, 2023
March 8, 2023 The rule needs to be clearer as to what a diversified fund is. Is concentration 25% (as it is used in the Investment Company Act? Is it 80% as is the threshold for the fund Names Rule? Is concentration based on sector (energy), industry (natural gas) or subsector (Natural gas pipelines)? As additional examples: +A global fund says it may investment more than 25% in a single country. Is it concentrated? +An SP 500 is currently has more than 25% allocated to technology, is it concentrated? I recommend just having the staff report all funds. If you are automating the reporting process, then there is no burden to require reporting of diversified funds. I am concerned about providing third-party to access our financial information. I assume this third-party will use robust cybersecurity protocols. However, the SEC and federal government has had cybersecurity incidents in the past with respect to employee data.