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On behalf of Simpson Thacher, Corporate Partners Sarah Cogan and Rajib Chanda, along with Corporate Associates Rafael Vasquez and Benjamin Wells, submitted a comment letter to the SEC on the new rule and amendment proposed by the Commission with respect to liquidity risk management. The letter addressed two specific items as to which comments were solicited by the Commission regarding closed-end Funds.

First, they support the Commission’s proposal to keep closed-end funds outside of the scope of proposed rule 22e-4, a new rule proposed under the Investment Company Act of 1940, as amended, as closed-end funds do not have the same liquidity needs as other forms of investment companies. Second, they recommend that the Commission allow closed-end funds the option of utilizing swing pricing, as it is possible that swing pricing could benefit certain closed-end funds, and hence the investors in such funds, and the Commission should not foreclose this option.

To read the letter in full, please click here.