March 27, 2018
Dear SEC,
I am an individual investor.
I support the SECs attempt to ensure that mutual funds and EFs remain liquid investment option for investors. That said, I think the SECs regulation of liquidity is a bit over the top. Very few funds (in fact I can only think of one) are unable to meet redemption requests because of liquidity concerns. So, it is a bit over the top to place such a strict regulatory regime around liquidity. I am happy that this rulemaking is pulling back on that rule. However, it does not go far enough.
The liquidity regime should codify the 15% limit of illiquid investment at all times and the SEC should come up with a reasonable definition for what an illiquid investment is. That alone, should be sufficient.
In addition, it is my understanding that the Commission is working on several other fund rulemakings. I believe that the SEC should hold off on any more investment company rulemakings until it starts received N-CEN and N-Port data. The SEC does not have the data it needs to make policy decisions. It is better to wait for that data to come in than to make uninformed decisions.
Thanks.
Todd Swain