Comment Letters
You can find the latest comment letters filed by the Forum on behalf of fund independent directors here.
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January 4, 2021
Forum Comment Letter: Tailored Shareholder ReportsOn January 4, 2021, the Forum submitted a comment letter in response to the SEC’s recent rule proposals regarding Tailored Shareholder Reports.
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July 21, 2020
Forum Comment Letter on Fair Valuation ProposalOn July 21, 2020, the Forum submitted a comment letter in response to the SEC’s recent rule proposal regarding the good faith determination of fair value.
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April 9, 2020
Forum Comment Letter on DerivativesOn April 9, 2020, the Forum submitted a comment letter in response to the SEC’s rule proposal use of derivatives by Registered Investment Companies and Business Development Companies.
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June 12, 2019
Forum Comment Letter on Securities Offering Reform for CEFOn June 12, 2019, the Forum submitted a comment letter in response to the SEC’s rule proposal regarding securities offering reform for closed end investment companies.
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May 2, 2019
Forum Comment Letter on Securities Offering Reform for CEF Learn more -
May 2, 2019
Forum Comment Letter on Fund-of-Funds Proposal Learn more -
May 2, 2019
Forum Comment Letter on Fund-of-Funds ProposalOn May 2, 2019, the Forum submitted a comment letter in response to the SEC’s proposal to govern fund-of-funds relationships by rule rather than through the exemptive process.
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October 3, 2018
Forum Comment Letter on ETF Proposal Learn more -
October 3, 2018
Forum Comment Letter on ETF ProposalOn October 1, 2018, the Forum submitted a comment letter in response to the Commission's rule proposal permitting ETFs that satisfy certain conditions to operate without the expense or delay of obtaining an exemptive order.
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July 12, 2018
Forum Comment Letter on SEC's Loan Rule Proposal Learn more -
July 12, 2018
Forum Comment Letter on SEC's Loan Rule ProposalOn July 9, 2018, the Forum submitted a comment letter in response to the Commission's rule proposals regarding Auditor Independence with Respect to Certain Loans or Debtor-Creditor Relationships. In the letter, the Forum supporting the Commission's revised approach to auditor independence with respect to the loan provision.
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May 18, 2018
Forum Comment Letter on SEC Investment Company Liquidity Disclosure Learn more -
May 18, 2018
Forum Comment Letter on SEC Investment Company Liquidity DisclosureOn May 18, 2018, the Forum submitted a comment letter in response to the Commission's rule proposals regarding Investment Company Liquidity Disclosure.
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June 23, 2017
Forum Letter to SEC Chairman Clayton Learn more -
February 28, 2017
Forum Comment Letter on SEC's Universal Proxy Rule Proposal Learn more -
September 6, 2016
Forum Comment Letter on SEC's Proposal regarding Adviser Business Continuity and Transition Plans Learn more -
May 24, 2016
Forum Comment Letter on SEC Investment Company Reporting Modernization Proposal Learn more -
April 28, 2016
Forum Comment Letter on Transfer Agent Regulations Learn more -
March 29, 2016
Forum Comment Letter on SEC Derivatives Proposal Learn more -
March 28, 2016
Forum Comment Letter on Use of Derivatives by RICs and BDCsOn March 28, 2016, the Forum submitted a comment letter in response to the SEC’s rule proposal regarding use of derivatives by registered investment companies and business development companies.
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