September 23, 2015
As a mutual fund investor, I am opposed to proposed Rule 22c-1. What you refer to as "swing pricing", I believe represents the "Uber-fication" of the Funds industry by introducing surge pricing methodologies. Your attempt to protect remaining investors in the Fund is penalizing investors who may even have regimented trade activities (i.e. monthly withdrawals to fund their retirement)simply because they are transacting on the more common side of the market. I implore you to reconsider this part of the proposal and give a deeper look into potential unintended consequences. Moreover, I find it difficult to believe that this concept is going to be easily understood for many retail mutual fund investors on why they are executing at levels that differ from the NAV.