November 26, 2019
This is just another rule making in search of a problem to solve. 1 fund blew up And we have a liquidity rule costing $10 of millions.
One fund blew up because of fraud (and derivatives) (LJM) and we are going thru another exercise.
Lets wait to see whether the liquidity rule solves the derivatives issue (whatever that is).
I also find The release impenetrable and the approach send arbitrary. Why hold a fund to a yard stick they get to choose?
Why not limit derivatives use so that the notional value of derivatives cannot exceed net asset value.
Also, stop using e term of art notional value and use
Exposure.
Finally, why are SEC releases so long compared to the rest of the government? Why does the staff think everything in a release is part of a rule and just as binding as a rule?
Shorten the releases. If you cant explain the rule and rational in 30 pages, the rule is too complex.
Another idea. Instead of asking for a liquidity risk management program this year and a derivative risk program next year and something else in 3 years. Why not just manadate a risk management program.