Subject: File No. S7-16-15

October 5, 2015

Your liquidity rules are naive to say the least. How is a mutual fund to determine if it owns 7 days of liquidity without moving the price of the security? Liquidity in a specific stock can dry up very quickly. You are fooling yourself if you think you can monitor this.

With the exception of a few money market funds, this has not been an issue with mutual funds. They have dealt with liquidity issues successfully for over 70 years and the government should stay out of this very successful $60 Trillion industry.