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Two things to consider:I'm still trying to get my head wrapped around the concept that the same security could be classified differently with respect to liquidity by two funds, even managed by the same company
I'm still trying to get my head wrapped around the concept that the same security could be classified differently with respect to liquidity by two funds, even managed by the same company (Final Rule, p. 100):We also are adopting a 15% limitation on funds’ purchases of illiquid investments, largely as proposed, but the definition of investments considered illiquid and subject to this 15% limit has been enhanced and substantially harmonized with the classification system we are adopting today.
Yes, that says "similar investments", not literally the same security, but SEC clarified in its FAQ (Q5): "Q: May different funds classify the same investment differently? A: Yes [then discusses the section of the Final Rule quoted above]"We recognize that, although we are providing a uniform classification framework, different funds may still classify the liquidity of similar investments differently, based on the facts and circumstances informing their analyses. This simply reflects the fact that different funds likely have different views on liquidity based on considerations such as their assessment of various market, trading, and investment-specific factors, and the size of their position in a particular investment. We acknowledge that liquidity can be difficult to estimate and that there is no agreed-upon measure of liquidity for all asset classes
The thing that's so laughable about this argument is that any fund shop investing in illiquid assets that isn't completely devoid of investment acumen would be assessing the liquidity of those assets anyway. They know internally what liquidity buckets those assets belong in. So why can't they disclose those buckets to shareholders and how will such disclosure be "consuming a disproportionately large amount of resources?" It's nonsense.The mutual-fund industry has panned what some analysts called the “bucketing” requirement, saying it requires them to make imperfect judgments about liquidity that could expose them to second-guessing by regulators and influential fund analysts such as Morningstar Inc.
“It is the industry’s single greatest concern with the rule,” said John Baker, a lawyer specializing in mutual funds at Stradley Ronon Stevens & Young LLP in Washington. “It’s very difficult to implement, it’s consuming a disproportionately large amount of resources, and there is real doubt as to how valuable this information will be to the SEC.”
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