The SEC’s proposed framework to modernize mutual fund disclosure requires modifications to better satisfy investor preferences and reduce costs for investors, according to a comment letter filed with the agency by the Investment Company Institute.
The mutual fund trade group also said the Securities and Exchange Commission should “make it easier for funds to e-deliver information to them.”
ICI provided input on three specific aspects of the SEC’s proposal:
Regarding Rule 30e-3, which covers distribution of shareholder reports, ICI said the commission should retain the rule without amending it and allow shareholders to choose whether to receive a notice about the availability of a shareholder report or to receive the full report.
ICI said that the shorter length and streamlined style of the SEC’s proposed shareholder report would make it easier for investors to understand key information and that the proposed report is similar to a prototype that ICI created and tested with investors. But instead of requiring funds to briefly describe any material change that happened during a particular period of time, ICI’s letter recommends that the fund determine which changes to include in the report and include them in a prominent and consistent location.
Finally, in the area of disclosing principal risks, ICI strongly discouraged the SEC from implementing an approach that would require a fund to assess whether a risk is a principal risk by considering whether it would place more than 10% of a fund’s assets at risk and if it would likely meet that threshold in the future. It recommended that the SEC retain its principles-based approach to risk disclosure.
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