October 1, 2015
I would like to voice my support for swing pricing. I agree that redeeming investors should bear the burden of transaction costs associated with that redemption. However, I think this should be limited, for instance to 1% of NAV so that an investor has some concept of the amount they will get.
I am opposed on the new restrictions on liquidity. Instead, I think you should stick to the current 15% limit on illiquid investments, but this should be an ongoing requirement (and not limited to the time of purchase). It does not make sense to limit this requirement to the time of purchase as open-end funds must always be redeemable.
Note: There has not been a liquidity crisis in the open-end fund space, so I am not sure what this rule is trying to solve for, other than to preempt efforts by other regulators and FSOC.
Also, while not part of the rule, I think the Commission should rethink rule 2a-4 which permits the calculation of NAV based on the prior days holding. Such a concession to the industry has no place in 2015.