MFA submitted a comment letter to the Board of the International Organization of Securities Commissions (IOSCO) in response to its Consultation regarding valuations.
In the letter, MFA:
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Supports IOSCO’s effort, with boundaries
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MFA supports IOSCO’s valuation‑standards update but stresses that the Recommendations must remain limited to open‑end retail funds, not private funds with fundamentally different structures and risk profiles.
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Encourages flexibility over prescription
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MFA urges flexible, principles‑based valuation governance, warning against prescriptive rules (e.g., mandated committees, model checks, stale‑valuation triggers) that conflict with existing, effective frameworks under SEC, AIFMD, and IFRS/ASC standards.
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Urges IOSCO to avoid duplication
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Private funds already operate under robust valuation, oversight, and recordkeeping regimes, so IOSCO should avoid duplicative mandates and ensure proportionality, particularly for smaller managers.
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