Comment Letter Content

ICI submitted this response to the OECD’s Progress Report on Amount A of Pillar One (“Progress Report”). Pillar One, among other things, would provide market jurisdictions with a new right to tax a portion of the allocable “residual profits” (Amount A) of large multinational entities...

On August 8, ICI filed this letter with the Securities and Exchange Commission to supplement our comments on the proposed reforms to money market funds. We added to our comments regarding the swing pricing requirements in the proposal. Our primary concern focused on ensuring that the...

In June, the SEC issued a request for comment on index providers, model portfolio providers, and pricing services. The release poses many questions exploring whether information providers might meet the definition of "investment adviser" under the Investment Advisers Act of 1940...

On August 16, 2022, ICI submitted a comment letter on the SEC's proposal for new disclosure requirements for investment companies and investment advisers. The letter expresses ICI's support for the fundamental goals of the Commission's proposal: to mitigate the risk of greenwashing...

At the end of May, the Securities and Exchange Commission proposed amendments to Rule 35d-1 (Names Rule) under the Investment Company Act of 1940 and new requirements related to disclosure and reporting by funds. ICI filed comments on August 16. In our letter, we described serious...

The Independent Directors Council responded to the Commission’s request for comment regarding whether, under certain circumstances, the activities of index providers, model portfolio providers, and pricing services (Information Providers) warrant investment adviser status. We...

The Independent Directors Council appreciates the opportunity to comment on the Securities and Exchange Commission’s proposal to amend Rule 35d-1 under the Investment Company Act of 1940 (the “Names Rule”). The proposal seeks to expand the universe of funds that are required to adopt...

Last week, ICI filed the attached comment letter on the North American Securities Administrators Association's request for comment on proposed amendments to its Statement of Policy Regarding Real Estate Investment Trusts. Although the proposed amendments would apply most directly to...

ICI's response to the European Financial Reporting Advisory Group (EFRAG) on the European Sustainability Reporting Standards (ESRS) Exposure Drafts is attached. Some highlights: Our letter encourages the EFRAG, as it develops the ESRS, to integrate and build directly on the global...