Feb. 2, 2023
Dear Chairman Gensler, I am writing in opposition to File Number S7-26-22, the SEC’s proposed rule on open-end fund liquidity and swing pricing. My mutual funds are a key part of my retirement plan. The SEC’s proposed rule to mandate swing pricing will limit options for long-term savers. Implementing the ‘hard close’ will likely make it difficult for my 401(k) plan to place timely trade orders . While the SEC’s proposal is about liquidity, it fails to note that mutual funds are highly liquid products. The SEC should review the Investment Company Institute data before recommending such drastic changes that have no obvious benefit to shareholders. The SEC’s proposal would fundamentally disrupt funds’ current practices, upend long-standing approaches to calculating share prices, and ultimately make investing more confusing for everyday Americans trying to retire or save for their long-term goals. The SEC needs to drop this proposal and go back to the drawing board. Best, Peter Strelow