The U.S. Chamber of Commerce’s (“the Chamber”) Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to comment on the proposal by the Securities and Exchange Commission (the “Commission”) that would amend its current rules for open-end funds regarding their liquidity risk management programs, require the use of swing pricing by open-end funds, and implement a “hard close” for open-end funds (the “Proposal”).
At the outset, the Chamber believes that the proposal should be withdrawn because of the lack of an appropriate cost-benefit analysis and the proposal also fails to meet the tripartite mission of the Commission to facilitate investor protection, capital formation and competition.