Subject: S7-26-22 Open-End Fund Liquidity Risk Management Programs and Swing Pricing Form N-PORT Reporting
From: Gregory Brandano
Affiliation:

Nov. 11, 2022



I support the S7-26-22 rule proposal. Funds need to be meeting more accurate margin requirements and the SEC needs to be implementing hard closes and improving liquidity risk management. Swing pricing absolutely should be a requirement of balancing these positions. This rule proposal is a step in the right direction to require funds to report information and post collateral; but it should go further. Instead of 60 days wait time for reports to be public, it should be 5 days.

It’s hard for me to imagine a scenario in which it benefits a retail investor to have to wait 60 days to see fiscal reports. The SEC tells retail investors to do research. The more research I do, the more feckless the institution reveals itself to be. Get an enforcement regime going that will inspire confidence in market fairness. The current atmosphere is one of corruption.


Sincerely,

Greg Brandano
Retail Investor