ICI submitted this letter to the Internal Revenue Service (IRS) with recommendations on how to utilize funds provided under the Inflation Reduction Act. The letter recognizes that this historic funding has the potential to transform and modernize taxpayer service capabilities and...
On October 25, ICI submitted the attached follow-up letter to SEC Chair Gary Gensler on the applicability of Rule 15c2-11 to fixed-income securities, particularly to Rule 144A debt securities. ICI previously joined several industry associations last fall in submitting an initial...
On October 11, 2022, the Institute sent the attached comment letter to the Department of Labor (DOL) in response to its proposed amendments to Prohibited Transaction Class Exemption 84-14 ("PTE 84-14"), a longstanding exemption governing financial institutions acting as qualified...
Earlier this week, ICI submitted supplemental comments (linked below) on the SEC's 2020 disclosure proposal for open-end funds ("funds"). On September 15, the SEC's Office of the Investor Advocate filed with the SEC a research paper on funds' choice of performance benchmarks and...
ICI filed this comment letter with the CFTC on its DCO governance rule proposal and the SEC on its registered clearing agency governance and conflicts of interest rule proposal. ICI's letter expresses support for the proposals, which would codify standards for DCOs and registered...
On October 3, ICI co-signed a letter with several associations (the Associations) in response to a consultation by the Prudential Regulatory Authority of the Bank of England (PRA) and the Financial Conduct Authority (FCA). The consultation sought comments on the proposal to amend on...
On October 3, 2022, ICI filed a comment letter on behalf of members discussing certain concerns with the proposals that many members had. We filed one letter to both FINRA and MSRB. The FINRA proposal sought comment on reducing the trade reporting timeframe for transactions in TRACE...
In July 2022, the SEC proposed amendments to Rule 14a-8 (the shareholder proposal rule) by a 3-2 vote. The proposal would narrow three bases upon which companies may exclude shareholder proposals from their proxy statements: the “substantial implementation,” “duplication,” and...
On August 19, ICI filed a comment letter discussing member views regarding the issues raised in the US Department of the Treasury ("Treasury") request for information on the possibility of additional post-trade transparency of data for secondary transactions in Treasury securities...
ICI submitted this response to the OECD’s Progress Report on Amount A of Pillar One (“Progress Report”). Pillar One, among other things, would provide market jurisdictions with a new right to tax a portion of the allocable “residual profits” (Amount A) of large multinational entities...
