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Fund of Funds Rule

Summary

SIFMA AMG sent comments to the United States Securities and Exchange Commission on the Commission’s proposed new Rule 12d1-4 under the Investment Company Act of 1940, as amended, that would streamline and enhance the regulatory framework applicable to funds that invest in other funds (“fund of funds” arrangements) (the “Proposed Rule”).

In addition, AMG is also providing comments on the Commission’s proposal to rescind Rule 12d1-2 and certain exemptive orders that have been granted to funds of funds and their sponsors, as well as the proposed amendments to Rule 12d1-1.

While AMG supports the object of the Proposal – to streamline and enhance the regulatory framework applicable to funds of funds and to create a consistent and efficient rules-based regime for the formation and oversight of funds of funds – we believe that the Proposal will unnecessarily disrupt many existing fund of funds arrangements.

PDF

Submitted To

SEC

Submitted By

SIFMA AMG

Related Committee(s)

  • Asset Management

Date

2

May

2019

Excerpt

Ms. Vanessa Countryman Acting Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: Fund of Funds Arrangements File No. S7-27-18

Dear Ms. Countryman:

The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to provide comments to the United States Securities and Exchange Commission (the “Commission”) on the Commission’s proposed new Rule 12d1-4 under the Investment Company Act of 1940, as amended (the “Investment Company Act” or the “1940 Act”), that would streamline and enhance the regulatory framework applicable to funds that invest in other funds (“fund of funds” arrangements) (the “Proposed Rule”). In addition, AMG is also providing comments on the Commission’s proposal to rescind Rule 12d1-2 and certain exemptive orders that have been granted to funds of funds and their sponsors, as well as the proposed amendments to Rule 12d1-1 (together with the Proposed Rule, the “Proposal”).2 While AMG supports the object of the Proposal – to streamline and enhance the regulatory framework applicable to funds of funds and to create a consistent and efficient rules-based regime for the formation and oversight of funds of funds – we believe that the Proposal will unnecessarily disrupt many existing fund of funds arrangements. To assist the Commission in improving the Proposed Rule, AMG sets forth below a number of specific comments and suggestions regarding the Proposal.

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