Comment Letter Content

ICI submitted a comment letter to the SEC's on their proposal for liquidity, swing pricing, hard close, and Form N-PORT. The proposal would radically change the liquidity risk management requirements for open-end funds (i.e., mutual funds and ETFs), impose on mutual funds a "hard...

ICI Global submitted a response to the online questionnaire for the ESAs Call for Evidence on Better Understanding Greenwashing. The attached document reflects the answers we provided to select questions in the questionnaire. Read more in the comment letter.

The Investment Company Institute (ICI) and ICI Global provided feedback on the Financial Conduct Authority (FCA) consultation on Sustainability Disclosure Requirements (SDR) and investment labels (“Consultation Paper”). ICI’s mission is to strengthen the foundation of the asset...

ICI Global submitted the attached response to a consultation from Japan Financial Services Agency (FSA) on proposed partial amendments to the comprehensive supervisory guidelines for financial business operators regarding ESG Investment Trusts. The proposed revisions seek to provide...

ICI Global thanks the Indian Government for the opportunity to submit recommendations for the Indian Government’s consideration as it considers the 2023 Indian Union Budget. We appreciate and welcome the Indian Government’s receptiveness to providing tax certainty to Foreign Portfolio...

The Independent Directors Council (IDC) commented on the Securities and Exchange Commission’s (Commission) proposed rule on outsourcing by investment advisers, Rule 206(4)-11 under the Investment Advisers Act of 1940 (Advisers Act). The proposed rule would establish due diligence and...

On December 23, 2022, the ICI filed a comment letter with the Securities and Exchange Commission on its proposal entitled "Outsourcing by Investment Advisers." The SEC has proposed a new rule, Rule 206(4)-11, under the Investment Advisers Act of 1940 (the "Advisers Act"), that would...

On December 23, ICI filed a comment letter with the Securities and Exchange Commission on its proposed rules ("Proposal") that would mandate the clearing and settlement of certain secondary market transactions in US Treasury securities in which one of the counterparties is a direct...

ICI's response to the Financial Stability Board's (FSB) consultative document on Achieving Greater Convergence in Cyber Incident Reporting (CIR) is summarized below. The FSB's consultative document invited feedback on three areas: Challenges to achieving greater convergence in CIR...

ICI submitted this letter asking the Treasury Department and the Internal Revenue Service (IRS) to provide regulatory relief exempting certain registered investment funds from the tax provisions enacted by the Inflation Reduction Act of 2022 (the "Act"). Specifically, the new...