The Investment Company Institute is writing to supplement our prior comments on the Securities and Exchange Commission’s proposal (“Proposal”) to amend Rule 35d-1 under the Investment Company Act of 1940 (“Names Rule”). This supplemental letter focuses specifically on certain aspects...
The Investment Company Institute appreciates the opportunity to provide its comments in response to the U.S. Securities and Exchange Commission reopening the comment period on the rule it proposed last year that would require registered investment companies and investment advisers to...
In February, the Financial Conduct Authority (FCA) published a discussion paper on updating and improving the regime for asset management in the United Kingdom (UK). We submitted the attached response on May 21, making the following two high-level points, as well as comments on...
The Investment Company Institute (ICI) is writing to reiterate our concern with the prospect of the Securities and Exchange Commission requiring certain registered investment companies (funds) to disclose their carbon footprint and weighted average carbon intensity (WACI) before...
The Investment Company Institute fully agrees with the Commission’s goals to protect the integrity of investor assets from risk of loss, misuse, theft, or misappropriation. ICI believes, however, that the Proposal places onerous new responsibilities on custodians and advisers and...
The Investment Company Institute (ICI) writes to reiterate our significant concerns with the Department of Labor’s (the “Department”) proposed amendments to Prohibited Transaction Exemption 84-14 (the “QPAM Exemption”), the longstanding exemption governing financial institutions...
The Investment Company Institute (“ICI”) submitted this comment on the Industry Guidance (the “Guidance”) proposed by the New York Department of Financial Services (“NYDFS”) regarding the presumption of control that applies to both New York chartered depository institutions (“Banking...
The Investment Company Institute (ICI) is writing to respond to the Securities and Exchange Commission’s (SEC or “Commission”) rule proposal (“Proposal”) to amend Regulation National Market System (“Regulation NMS”) to establish variable minimum pricing increments (“tick sizes”) for...
On March 31, 2023, ICI filed a comment letter on the SEC's proposals for Regulation Best Execution and the Order Competition Rule issued by the SEC on December 14, 2022. Proposed Regulation Best Execution would establish a new SEC-level standard regarding a broker-dealer's duty of...
The Investment Company Institute appreciates the opportunity to comment on the Securities and Exchange Commission’s (SEC or “Commission”) re-proposal of a rule to prohibit conflicts of interest in certain securitization transactions (“Re-Proposed Rule”). The rule would implement the...
