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ICI Default BG
Memo#
34934

ESG-Related Developments (November 22, 2022–February 2, 2023)

This memorandum catalogues significant ESG related developments that have occurred since November 22, 2022. It references, where indicated, ICI memoranda that provide a more fulsome description of each matter. You can find all of these memoranda on our website in our ESG Resource...
ICI Default BG
Memo#
34881

IM Staff Issues Guidance on Differential Advisory Fee Waivers

The staff of the SEC's Division of Investment Management recently issued a reminder to mutual funds and their boards that fee waiver and expense reimbursement arrangements that are long-term or permanent (or effectively long-term or permanent) and that result in different advisory...
ICI Default BG
Memo#
34857

US Federal Reserve Adopts Final LIBOR Act Rule

On December 16, 2022, the Board of Governors of the Federal Reserve System (the "Board") issued a final rule ("Final Rule") implementing the US Adjustable Interest Rate (LIBOR) Act, which was enacted on March 15, 2022. The Final Rule establishes the benchmark replacements that will...
ICI Default BG
Memo#
34839

2023 Report on FINRA's Examination and Risk Monitoring Program

The Financial Industry Regulatory Authority ("FINRA") recently issued its 2023 Report on FINRA's Examination and Risk Monitoring Program. The report addresses, among other topics, member firms' communications promoting ESG factors. It describes findings from recent oversight...
ICI Default BG
Memo#
34804

SEC Staff Issues New Investment Adviser Marketing Rule FAQ

On January 11, 2023, the Securities and Exchange Commission Division of Investment Management staff issued a new FAQ regarding the presentation of gross and net performance of a single investment or a group of investments in a private fund under the Investment Adviser Marketing Rule.
ICI Default BG
Memo#
34786

SEC and CFTC Rulemaking Agendas

The Office of Information and Regulatory Affairs released the Fall 2022 Unified Agenda of Regulatory and Deregulatory Actions on January 4, 2023. The agenda includes regulatory actions that the Securities and Exchange Commission and Commodity Futures Trading Commission expect to take...
ICI Default BG

ICI Welcomes the Improving Disclosure for Investors Act

The bipartisan ‘Improving Disclosure for Investors Act’ is an important step forward in modernizing delivery of investor disclosures. This bill reflects their strong preference to receive disclosure documents electronically, which also helps investors find the information that is most...