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Comment Letter - SEC’s proposal on open-end fund liquidity risk management programs and swing pricing


In our comment letter, we recommend that the SEC clarify the auditor’s role in evaluating the application of swing pricing to adjust a fund’s net asset value per share, which all open-end mutual funds (except for money market funds and exchange-traded funds) would be required to do under the proposed rule. Our comments also address the financial statement presentation and disclosures for swing pricing and certain alternatives to swing pricing and a hard close requirement, such as the application of dual pricing and simplified swing pricing.

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