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Vedder Thinking | News Vedder Price Investment Services Group Submits Comment Letter on SEC’s Swing Pricing/Hard Close Proposals

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On behalf of Vedder Price’s Investment Services Group, Shareholders Maureen A. Miller, Jacob C. Tiedt and Nathaniel Segal submitted a letter responding to the request by the SEC for comments on the rule proposals set forth in Investment Company Act Release No. 34746 (File No. S7-26-22), Open-End Fund Liquidity Risk Management Programs and Swing Pricing, and Form N-PORT Reporting.  The rule proposals were issued on November 2, 2022, and the comment period ended on February 14, 2023.

The rule proposals would potentially require open-end funds, with some limited exceptions, to employ swing pricing and to implement a “hard close” generally by 4:00 p.m. Eastern time. Vedder Price’s letter to the SEC noted that the rule proposals could inhibit investor choice and competition, introduce significant operational challenges, prove disadvantageous for investors in certain time zones and fundamentally change the process by which retirement plans currently operate.

Vedder Price’s letter contained suggested alternatives for the SEC to consider as it evaluates the comments provided on the swing pricing and hard close proposals.

To read the comment letter in full, please click here. The SEC’s proposing release containing the rule proposals can be found here.


Maureen A. Miller


Jacob C. Tiedt


Nathaniel Segal