Comment Letters

Comment Letters


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ICI Default BG

ICI Comment Letter on Fund Names (pdf)

1 2 3 4 5 1 2 . 3 4 5 2 15 6 I. Executive Summary 7 8 9 6 7 8 9 3 15 • We agree that funds today use derivatives in a variety of ways and that the asset-based testing approach of the Names Rule, derivatives for Names Rule purposes, raises challenges for funds that gain investment...
ICI Default BG

Comment Letter on SEC Proposed Derivatives Rule 18f-4 (pdf)

April ,  Ms. Vanessa A. Countryman Secretary Securities and Exchange Commission  F Street, NE Washington, DC  Re: Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered Investment...
ICI Default BG

IDC Comment Letter on Derivatives Proposal (pdf)

April 20, 2020 Ms. Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549-1090 Re: Use of Derivatives by Registered Investment Companies and Business Development Companies; Required Due Diligence by Broker-Dealers and Registered...