Securities Law Prof Blog

Editor: Eric C. Chaffee
Univ. of Toledo College of Law

Friday, February 29, 2008

SIFMA Files Comments on Mutual Fund Reform

SIFMA today filed a comment letter in support of most aspects of the SEC's  proposed disclosure and new prospectus delivery option for mutual funds.  The SEC reforms would require preparation and delivery of a summary prospectus written in plain English to replace the current mutual fund prospectus which the SEC itself recognizes does a poor job of providing information to prospective mutual fund investors.  The summary prospectus would contain seven categories of information most important to investors, including investment objectives, costs, strategies and risks, among others.

SIFMA, however, in a joint letter with the Investment Company Institute, did raise objections to the SEC’s proposal that a summary prospectus include quarterly updates of performance and portfolio holdings. They assert that requiring quarterly updates would reduce the industry’s incentive to utilize the summary document, due to the significant administrative and operational burdens it would create.

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