Key Considerations:

• Common Components of OEF Structure:
  – Support for IOSCO’s categorization but caution against rigid classifications.
  – Asset liquidity should guide redemption terms, but labeling funds as “liquid” or “less liquid” may be misleading in crises.
  – Emphasis on early regulatory engagement and practical fund structures.
• Liquidity Management Tools (LMTs):
  – Support for anti-dilution measures like swing pricing and redemption gating.
  – LMTs should be applied only in cases of material dilution, not as a daily practice.
  – Consideration of the impact on smaller investors when implementing LMTs.
• Governance and Market Conditions:
  – Support for proportional governance structures.
  – Importance of empirical market intelligence, especially in less efficient markets.
  – Balance between regulatory oversight and industry flexibility.

• Disclosure and Transparency:
  – Transparency is important, but excessive disclosure could trigger investor panic.
  – LMT activations should be disclosed, but duration details should remain flexible to prevent front-running.

• Additional Comments:
  – Concerns over accessing investor concentration data and calculating implicit liquidity costs.
  – Call for a best-efforts approach to accommodate jurisdictional differences.