THE INVESTMENT TRUSTS ASSOCIATION, JAPAN (TOSHISHINTAKU KYOKAI) TOKYO STOCK EXCHANGE Bldg., 2-1, NIHONBASHI KABUTOCHO, CHUO-KU, TOKYO, JAPAN 103-0026 TEL:81-3-5614-8400 FAX:81-3-5614-8448 October 17th, 2016 International Organization of Securities Commissions (IOSCO) Calle Oquendo 12 28006 Madrid Spain Dear Dr. Shane Worner, Re: Good Practices for the Termination of Investment Funds - Consultation Report I. Preface The Investment Trusts Association, Japan ( hereafter, “JITA”) appreciates the opportunity to provide its comment in response to the Consultation Report, “Good Practices for the Termination of Investment Funds” which was made public on August 18th, 2016. JITA was established in July 1957 under a license of the Minister of Finance, which was the governing authority at that time, for the purposes of protecting investors and promoting sound development of investment trusts in Japan. JITA is positioned as ‘Authorized Financial Instruments Firms Association’ under the Financial Instruments and Exchange Act of Japan, and the purposes and the scope of business of JITA are defined by the Act. JITA comprises of 167 full members including investment trust management companies and REIT management companies as well as 21 supporting members including securities companies and custodian banks as of October 2016. I would like to convey the comments received from JITA members regarding the Consultation Report. 1 II. Comment on ‘C. Decision to Merge’ in the Consultation Report: The principles on the termination of the funds are important for investor protection. In deciding on the termination of funds, it also has to be recognized, as indicated in ‘C. Decision to Merge’ in the consultative document, that there may be cases where it would be better for investors for the fund to be merged with other funds rather than to be terminated. In this regard, it would be helpful to add to the explanatory note of ‘C. Decision to Merge’ that there could be some cases that the merger of the fund would contribute to greater benefits to investors and better protecting investors instead of its termination. The institutional impediments that would prevent such merger should be reviewed and removed, where possible. Sincerely yours, Yoshio Okubo Vice Chairman The Investment Trusts Association, Japan 2 .