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June 19, 2017 TO: ICI MembersInvestment Company Directors
ICI Global Members
Advertising Compliance Advisory Committee
Broker/Dealer Advisory Committee
Principal Underwriters Working Group
SEC Rules Committee
Small Funds Committee
Transfer Agent Advisory Committee SUBJECTS: Advertising
Compliance RE: ICI Files Comment Letter with FINRA in Response to Special Notice
On June 19, 2017, ICI filed the attached comment letter with FINRA, responding to its Special Notice soliciting comment on FINRA’s current engagement programs.[1] This request for comments is one of the first steps in FINRA’s new initiative to evaluate various aspects of its operations and programs to identify opportunities to more effectively further its mission.
ICI’s comment letter supports FINRA’s initiative to engage with the regulated fund industry to identify ways to tailor and make more effective its regulatory programs. In summary, (i) we support FINRA conducting retrospective rule reviews and disseminating information to its members through FAQs and Regulatory Notices; and (ii) we recommend improving FINRA’s rulemaking process by lengthening the comment period and providing more meaningful responses to comments that identify concerns with FINRA proposals.
Linda M. French
Assistant General Counsel
endnotes
[1] See ICI Memorandum No. 30663, available at https://www.iciglobal.org/iciglobal/pubs/memos/memo30663.