Comment Letter Content

On March 31, 2023, ICI filed a comment letter on the SEC's proposals for Regulation Best Execution and the Order Competition Rule issued by the SEC on December 14, 2022. Proposed Regulation Best Execution would establish a new SEC-level standard regarding a broker-dealer's duty of...

The Investment Company Institute appreciates the opportunity to comment on the Securities and Exchange Commission’s (SEC or “Commission”) re-proposal of a rule to prohibit conflicts of interest in certain securitization transactions (“Re-Proposed Rule”). The rule would implement the...

The undersigned Associations, which together represent a significant portion of the financial services industry, including banks of all sizes, global custodians, broker-dealers, investment funds, fund managers, alternative investments and registered investment advisers, respectfully...

The Financial Conduct Authority's (FCA) discussion paper on the Future Disclosure Framework seeks feedback on how the FCA can design and deliver a good disclosure regime that is "supportive, engaging, accessible, and flexible," as well as future-proof. It specifically asks for input...

ICI Global recently submitted a comment letter in response to a consultation issued by HM Treasury as the first step in the UK Government's process of establishing an alternative disclosure regime for the United Kingdom (UK) that fosters retail investor participation and repeals EU...

The undersigned fund industry associations, on behalf of their regulated fund members, strongly urge the Indian Government to make permanent the concessional income-tax rate regime introduced by the Finance Act, 2013 for FPIs by virtue of amendments brought about to section 115AD read...

The Investment Company Institute (“ICI”) appreciates the opportunity to provide comments in response to the notice of proposed rulemaking (“NPRM”) issued by the Financial Crimes Enforcement Network (“FinCEN”) to implement provisions of the Corporate Transparency Act (“CTA”) that...

ICI Global appreciates the opportunity to provide feedback on the European Securities and Markets Authority (ESMA) Consultation Paper on guidelines on funds’ names using ESG or sustainability-related terms (“Consultation Paper”). ICI Global carries out the international work of the...

The Investment Company Institute (ICI) and ICI Global appreciate the opportunity to provide feedback on the Australian Treasury (Treasury) consultation on the development of a climate-related financial disclosure framework in Australia (“Consultation Paper”). As the trade association...

The Independent Directors Council submitted this comment letter to the SEC on their proposal to require swing pricing and a hard close for mutual funds, change Form N-PORT filers' reporting obligation, and amend the liquidity rule for open-end funds (Proposal or Release). In...