On July 9, 2018, the Forum submitted a comment letter in response to the Commission's rule proposals regarding Auditor Independence with Respect to Certain Loans or Debtor-Creditor Relationships. In the letter, the Forum supporting the Commission's revised approach to auditor independence with respect to the loan provision.
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Forum Comment Letter on SEC Investment Company Liquidity Disclosure
On May 18, 2018, the Forum submitted a comment letter in response to the Commission's rule proposals regarding Investment Company Liquidity Disclosure. In the letter, the Forum reiterates the view that liquidity risk management is an important issue for all funds and that fund boards have an important role to play in overseeing the manner in which this risk is managed, but also conveys concerns about the Commission’s approach to liquidity risk management – in particular, concerns of the Forum membership that the recently adopted requirement that funds classify every portfolio security into a specific “liquidity bucket” will impose significant costs on funds and their shareholders without producing commensurate benefits or otherwise improving the manner in which the industry manages liquidity risk.
Forum Comment Letter on SEC's Universal Proxy Rule Proposal
On February 27, 2017, the Forum submitted a comment letter in response to the Commission's rule proposals regarding the use of universal proxies in contested board elections. The Forum's letter voices support for the Commission's initial determination to exclude registered investment companies from its universal proxy proposal.
Forum Letter to SEC Chairman Clayton
On June 20, 2017, the Forum submitted a letter to the Chairman of the Securities and Exchange Commission discussing issues important to the independent fund directors who protect the interests of the millions of fund investors. The letter recommends that the Commission carefully and systematically analyze and define the role it intends for directors to play.
Forum Comment Letter on SEC's Proposal regarding Adviser Business Continuity and Transition Plans
On September 6, 2016, the Forum submitted a comment letter in response to the SEC’s proposal regarding adviser business continuity and transition plans. The Forum’s letter recognizes the importance of the issue given investors’ reliance upon a fund’s adviser’s ability to identify and manage risks related to its ability to operate continuously. However, the letter urges the Commission to consider offering staff guidance rather than specific requirements in light of the diversity represented in the adviser community.