SBIA Comment Letter: Proposed AFFE Amendments

December 4, 2020

Vanessa Countryman
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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