August 25, 2020
It is unclear to be why you are proposing this on the eve of rule 30e-3s rollout. Was 30e-3 ill-conceived? We have gone from a 100 page document to a post card to several 3 page documents (one per fund).
Similarly, you adopt the liquidity rule, you then back off bucketing and replace it with disclosure, and right when the requirement begins to take effect, you change it.
Like all of your rulemakings, take a step back, breathe and figure out your regulatory direction. You can fix what is broken, but you need to wait and see what works before changing it.
I also do not like the new expense example remove the performance.
I hate the change to AFFE. The current presentation is effective and nobody has said I to otherwise.