May. 02, 2019
May 2,2019
Brent J. Fields ,Secretary
U.S. Securities and Exchange Commission
100 F Street , NE
Washington ,DC 20549-1090
Re: Comments to Proposed Rule 12d1-4 File NumberS7-27-18
Secretary Fields :
I join other interested parties in commenting on the above-
Referenced proposed rule and write to express my concern with
its failure to address the closed-end fund industry. With the
increased activity of activist investors trying to gain quick returns
by disrupting activities such as forcing liquidity events or a tender
for their accumulated holdings, it is imperative that the existing
rules be revised to protect the long term investors in closed-end
funds. The Proposed Rule provides the opportunity to address these current abuses jeopardizing the closed-end fund industry
and its investors.
For a start, the Proposed Rule should be updated to ensure
that an acquiring fund and its affiliate group are limited to an
aggregate ownership of 3 percent. The aggregate ownership
rules should take into account all accounts managed by an
investment advisor or its affiliate for the purpose of ownership
limitations.
Short term activism and seeking short term results is in
direct conflict with the objective of long term investors and
small shareholders. I appreciate the opportunity to comment
on the Proposed Rule.
Sincerely,
Clarence A. Davis
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