Associations Request More Time to Comment on SEC Liquidity Risk Management and IA Outsourcing Proposals

In a joint letter, trade associations urged the SEC to extend the comment deadline by 90 days on proposals concerning open-end fund liquidity risk management programs and outsourcing by investment advisers.

In the letter, the Loan Syndications and Trading Association, Alternative Investment Management Association, Investment Adviser Association, U.S. Chamber of Commerce, SIFMA, the Investment Company Institute, American Investment Council and Managed Funds Association (collectively, "the Associations") expressed concern that the current deadline does not provide market participants adequate time to review the extensive and complex changes proposed under each proposal and simultaneously respond to the large volume of information requests from the SEC. The Associations also said that the current comment periods include several upcoming holidays, which would further limit the time market participants could dedicate to the proposals.

The Associations warned that a hasty implementation of the proposals (without adequate analysis) will likely cause confusion across the market, may create additional costs and may cause unintended consequences. The Associations said that the 90-day extension would provide a minimum amount of time reasonably necessary for stakeholders to thoughtfully and meaningfully assess the proposed rules.