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On August 31, MFDF submitted a comment letter to the Securities and Exchange Commission (SEC) regarding the staff’s Request for Comment on Novel ETFs. MFDF’s comment letter encouraged the Commission to better delineate what types of traded vehicles are eligible for RIC status under the Investment Company Act of 1940 and which fall under other regulatory schemes. Clarity for investors also would be enhanced by limiting the vehicles that can call themselves “ETFs” only to funds that are registered under the Investment Company Act. MFDF also encourages the Commission to consider requiring disclosure of material unresolved staff comments to the fund’s board before the fund’s registration statement becomes effective. 

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