Comment Letter Content

The undersigned asset and fund management associations, on behalf of our respective members, would like to share with SEBI the issues and challenges that we have with SEBI’s recent directions for Foreign Portfolio Investors (“FPIs”) in relation to disclosures of the details of their...

In this letter, we highlight serious concerns with the Council’s approach. As compared with the Current Guidance, the Proposals take a step backward in terms of the rigor required of FSOC’s analyses of perceived risks to financial stability and appear to lower the bar for Council...

The Investment Company Institute is writing to supplement our views on the Securities and Exchange Commission’s proposal to require enhanced Environmental, Social, and Governance (ESG) disclosures by certain advisers and investment companies. In so doing, we recognize, and express...

ICI Global submitted the attached response to the Australian Treasury on its second consultation on climate-related financial disclosure framework. The proposed framework would require entities (including financial institutions) lodging financial reports under Chapter 2M of the...

ICI Global appreciates the opportunity to provide feedback on the European Supervisory Authorities (ESAs) joint consultation on the review of the Sustainable Finance Disclosure Regulation (SFDR) Delegated Regulation regarding principal adverse impacts (PAI) and financial product...

The undersigned fund industry associations have substantial concerns with Australia’s draft proposal to require multinational tax transparency through public country-by-country (CbC) reporting. We strongly support the disclosure of information that promotes sound investment decisions...

In the April Commission Statement Relating to Certain Administrative Adjudications and the Second Commission Statement Relating to Certain Administrative Adjudications, the Securities and Exchange Commission (Commission or SEC) announced that there had been an ongoing internal breach...

The Investment Company Institute is writing to provide comments on the Securities and Exchange Commission’s (the “Commission” or SEC) supplemental information and reopening of the comment period for its proposal that would, among other things, amend Rule 3b-16 under the Securities...

The Investment Company Institute (ICI) is pleased to submit recommendations regarding retirement security issues for projects to be included on the 2023-2024 Priority Guidance Plan. A separate ICI submission describes our recommendations regarding regulated investment companies. ICI...

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...