October 8, 2015
As a retail investor, I am grateful to the Commission for considering better safeguards against liquidity risks in mutual funds.
Generally speaking, it is in the investing public's and financial markets' interests that more investors adopt buy-and-hold strategies (instead of rushing for the exits (or entrances) with everyone else when markets are volatile, thus exacerbating the volatility). Retail investors should ideally rely on diversification and smart asset allocation to manage most market risks.
One big hindrance toward that goal has been the uneasiness that many investors have felt about potentially being penalized for holding onto their mutual fund investments when mutual fund share prices drop and others rush to redeem their shares thus forcing liquidations of fund assets at unfavorable prices - a type of "externality" to which investors with stable hands did not subscribe.
Toward that end, the proposed swing pricing rules, to the extent that they place the burden of negative price swings in fund assets on the investor demanding a large redemption of fund shares, is a positive development.
In general, I ask that the Commission leave no stone unturned in freeing investors from the negative effects of redemptions of fund shares by others during market volatility. While the proposed rules seem focused on open-ended mutual funds, the Commission should not rule out devising better protection against potential swings in ETF asset prices caused by large block transactions between the ETF and institutional investors.