Subject: S7-04-23: Webform Comments from Business Administrative Journal
From: Business Administrative Journal
Affiliation:

Oct. 30, 2023

The implications of the recently announced SEC initiative
labeled "Reporting Requirements Related to Liquid Net Asset Value
('LNAV') Funds'" (Release No. IA-6240; File No.
S7-04-23), growing disapproval has emerged among diverse segments of
society. Industry professionals, trade organizations, and policymakers
alike share grave reservations regarding specific aspects of this
proposal, raising serious doubts over its feasibility, efficacy, and
legality. To illustrate, the Investment Company Institute,
representing approximately $28 trillion worth of mutual fund assets,
has voiced strong objections to several key elements of the suggested
regulation. According to their arguments, the required annual meeting
notice format mandated by the SEC risks compromising sensitive
business data, exposing valuable proprietary insights to competitors,
and inviting unwarranted litigation hazards. Moreover, the American
Bankers Association, encompassing thousands of banking institutions
nationwide, warns against the potential burden imposed upon community
banks and credit unions resulting from additional recordkeeping
demands, as they struggle to cope with mounting regulatory pressures
amidst ongoing economic uncertainty. Similarly, leading legislative
figures across both chambers of Congress have expressed apprehension
over the proposed measures, underscoring perceived flaws in their
execution and questioning their overall usefulness. Consequently, we
concur with the sentiments espoused by these respected constituents
and urge the SEC to consider their inputs diligently before finalizing
this initiative. It is vital that all stakeholders be heard and that
their viewpoints and experiences be duly acknowledged in shaping the
future course of regulatory action. In light of these circumstances,
we kindly encourage you to listen attentively to the voices of those
affected by these recommendations, weigh their opinions fairly, and
arrive at sound judgments based on solid evidence. Your decisions will
set precedents affecting countless individuals and businesses,
therefore, we trust that you will take appropriate steps to safeguard
their interests and preserve the integrity of capital markets as a
whole. Please allow us to submit detailed comments on this matter at
your convenience. Thank you for your attention to this matter.