Comment Letter Content

The Investment Company Institute is writing to supplement our prior comments on the Securities and Exchange Commission’s proposal (“Proposal”) to amend Rule 35d-1 under the Investment Company Act of 1940 (“Names Rule”). This supplemental letter focuses specifically on certain aspects...

The Investment Company Institute appreciates the opportunity to provide its comments on the proposal by the Securities Exchange Commission (the Commission or SEC) to require various SEC-covered entities, including broker-dealers and transfer agents, to adopt and implement written...

The Investment Company Institute supports the U.S. Securities and Exchange Commission’s proposal to supplement the requirements of Section 248.30 of Regulation S-P, which govern safeguarding of customer information, to require “covered institutions” to have more detailed and rigorous...

The Investment Company Institute appreciates the opportunity to provide its comments in response to the U.S. Securities and Exchange Commission reopening the comment period on the rule it proposed last year that would require registered investment companies and investment advisers to...

The Investment Company Institute (ICI) is writing to reiterate our concern with the prospect of the Securities and Exchange Commission requiring certain registered investment companies (funds) to disclose their carbon footprint and weighted average carbon intensity (WACI) before...

The Investment Company Institute fully agrees with the Commission’s goals to protect the integrity of investor assets from risk of loss, misuse, theft, or misappropriation. ICI believes, however, that the Proposal places onerous new responsibilities on custodians and advisers and...

The Investment Company Institute writes to request immediate guidance and relief relating to certain changes to the Internal Revenue Code (“Code”) enacted under the Consolidated Appropriations Act, 2023 (CAA). As you know, the CAA (signed by the President on December 29, 2022)...

The Investment Company Institute (ICI) writes to reiterate our significant concerns with the Department of Labor’s (the “Department”) proposed amendments to Prohibited Transaction Exemption 84-14 (the “QPAM Exemption”), the longstanding exemption governing financial institutions...

The Investment Company Institute (“ICI”) submitted this comment on the Industry Guidance (the “Guidance”) proposed by the New York Department of Financial Services (“NYDFS”) regarding the presumption of control that applies to both New York chartered depository institutions (“Banking...

The Investment Company Institute (ICI) is writing to respond to the Securities and Exchange Commission’s (SEC or “Commission”) rule proposal (“Proposal”) to amend Regulation National Market System (“Regulation NMS”) to establish variable minimum pricing increments (“tick sizes”) for...