Letters

The SEC’s Concept Release on the Use of Derivatives by Investment Companies

Summary

SIFMA Asset Management Group (AMG) provides comments to the Securities and Exchange Commission (SEC) on the SEC’s Concept Release: Use of Derivatives by Investment  Companies Under the Investment Company Act of 1940.  The SEC’s concept release requests comments on a wide range of issues relevant to Investment Companies, such as fund leverage, diversification, portfolio concentration, and valuation. Through public input, the SEC hopes to determine whether regulatory initiatives or guidance are needed to improve the current regulatory regime for funds.  SIFMA AMG recommends that the SEC fully assess the impact of the new regulatory framework on the derivatives markets before implementing any regulation on issues relating to this concept release.

Submitted To

SEC

Submitted By

SIFMA AMG

Date

23

November

2011