Enhanced Disclosure & New Prospectus Delivery Option For Registered Open-End Management Investment Companies

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s proposal to enhance disclosure and new prospectus delivery option for registered open-end management investment companies release. SIFMA fully supports the Commission’s effort but does not believe that portfolio holdings information is a necessary component of the summary prospectus. SIFMA also does not believe it is critical to update performance information in the summary prospectus on a quarterly basis since mutual funds are generally long-term investments.