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Better Markets Comment Letter to the SEC on Use of Derivatives by Investment Companies

On March 24, 2020, Better Markets submitted a comment letter on the Securities and Exchange Commission’s re-proposal of a new exemptive regulation establishing a number of sensible risk management, governance, and leverage requirements designed to mitigate risks associated with the use of derivatives by most registered open-end or closed-end funds and business development companies under the Investment Company Act of 1940.  Although we express significant reservations about certain elements of the re-proposal and in particular, the abandonment of the asset segregation framework and the intr