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.