Enhanced Disclosure & New Prospectus Delivery Options for Registered Open-End Management Investment Companies

SIFMA provides comments to the Securities and Exchange Commission (SEC) on enhanced disclosure and new prospectus delivery options for registered open-end management investment companies, Release No. 33-8949; File No. S7-28-07.  The SEC has re-opened the comment period on the summary prospectus proposal.  SIFMA believes the inclusion of any information in a summary prospectus requiring quarterly updating would cause significant administrative and operational burdens, which would create disincentives to its widespread use.  SIFMA previously submitted comments on the topic, February 28, 2008.