SBIA Comment Letter: AFFE Amendments
December 4, 2020
SEC ISSUE TRACKER
The Small Business Investor Alliance informs and educates its members on the issues that impact their ability to invest, and works to promote public policies that help small businesses gain access to the capital that is crucial to U.S. economic growth and American job creation.
BY ELECTRONIC TRANSMISSION
December 4, 2020
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: SEC File No. S7-09-20; Release Nos. 33-10814; 34-89478; IC-33963: SBIA Comments on Tailored Shareholder Reports, Treatment of Annual Prospectus Updates for Existing Investors, and Improved Fee and Risk Disclosure for Mutual Funds and Exchange-Traded Funds; Fee Information in Investment Company Advertisements
Dear Ms. Countryman:
The Small Business Investor Alliance (“SBIA”) appreciates the opportunity to comment on the Securities and Exchange Commission’s (“SEC”) proposed amendments to rules that require an open-end management investment company to disclose “acquired fund fees and expenses” (“AFFE”), i.e., its pro rata share of the operating expenses charged by underlying funds in which the fund invests, as an additional line item in its prospectus fee table (such disclosure requirement is referred to herein as the “AFFE Rule”).
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About the Small Business Investor Alliance (SBIA)
The Small Business Investor Alliance is the association of senior investment professionals focused on the lower middle market whose members represent the entire private capital ecosystem. It is an alliance for professional fellowship, business opportunities, innovation, regulatory expertise, and market data. SBIA works on behalf of its members as a tireless advocate for policies that promote competitive markets and robust domestic investment for growing small businesses. SBIA has been playing a pivotal role in promoting the growth and vitality of the private equity industry for over 60 years. For more information, visit www.SBIA.org or call (202) 628-5055.