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Securities Offering Reform for Closed-End Investment Companies

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the proposed rules and related amendments that would permit business development companies (BDCs) and registered closed-end fund investment companies (CEFs) to use certain securities offering and proxy rules that are already available to operating companies, as set forth in the SEC’d Proposed Rule Release No. 33-10619.

PDF

Submitted To

SEC

Submitted By

SIFMA

Related Committee(s)

  • Primary Markets Committee

Date

5

June

2019

Excerpt

June 5, 2019

Submitted via email to [email protected]

U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090

Attention: Vanessa A. Countryman, Acting Secretary

Re: Securities Offering Reform for Closed-End Investment Companies (File Number S7-03-19)

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 is writing to respond to the invitation of the Securities and Exchange Commission (the “Commission”) for public comment on the proposed rules and related amendments that would permit business development companies (“BDCs”) and registered closed-end fund investment companies (“CEFs” and, together with BDCs, “Affected Funds”) to use certain securities offering and proxy rules that are already available to operating companies, as set forth in the Commission’s Proposed Rule Release No. 33-10619 (the “Release”).2 We appreciate the opportunity to provide comments to the Commission on the Release.

We commend the Commission’s efforts to implement the Congressional mandates set forth in the Small Business Credit Availability Act and the Economic Growth, Regulatory Relief, and Consumer Protection Act by proposing rules and amendments that modernize and streamline certain public offering and communications processes applicable to Affected Funds. As discussed in more detail below, we agree with the Commission’s assessment that many of the proposals contained in the Release will facilitate capital formation and lower the cost of capital for Affected Funds in a manner that does not compromise investor protection.

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1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly one million employees, we advocate on legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. With offices in New York and Washington, DC, SIFMA is the U.S. regional member of the Global Financial Markets Association.
2 See 84 Fed. Reg. 14,448 (April 10, 2019).

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