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The IAA generally supported the proposal but recommended more flexibility regarding the reporting requirements, making the definition of “readily available market quotation” reflect current valuation practices, and flexibility for a fund board to assign the fair value determination to the fund’s primary adviser or sub-adviser.
The IAA generally supported the proposed derivatives rule, with certain modifications to reduce unnecessary burdens on advisers. The IAA strongly opposed the proposed sales practice rule for investment advisers related to retail investor transactions in leveraged/inverse investment vehicles because it is both duplicative of and inconsistent with the principles-based approach to fiduciary duty.
The IAA supported the objective of the proposal to make the applications process more efficient. The IAA also supported comments made by the Investment Company Institute regarding the expedited review process, transparency on the timeframe for staff action, and concerns on publication of comments and responses.
The IAA had significant concerns regarding the disruptive impact that the proposed limit on redemptions would have on fund management. The IAA also argued that private funds and foreign funds should be permitted to rely on the proposed rule.
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