Comment Letter Content

March 18, 2024—The Investment Company Institute and Independent Directors Council filed a joint supplemental comment letter on the Public Company Accounting Oversight Board's (PCAOB) proposed amendments to the auditing standards related to a company's noncompliance with laws and...

In late February, FINRA proposed to further amend Rule 2210 (Communications with the Public) (the "rule"). The amended proposal would permit a FINRA member to project performance or provide a targeted return with respect to a security or asset allocation or other investment strategy...

March 8, 2024—In this letter, ICI Global provided feedback to the Financial Conduct Authority (FCA) on its consultation paper on updating the regime for money market funds (MMFs). ICI’s members include mutual funds, UCITS, and exchange-traded funds, and similar funds offered in...

March 5, 2024—The Investment Company Institute (ICI) expresses our strong support for three bipartisan amendments being offered in consideration of HR 2799 – The Expanding Access to Capital Act of 2023 sponsored by Chairman Patrick McHenry. These three bipartisan amendments will go a...

On February 20, 2024, ICI submitted the attached comment letter to the Internal Revenue Service (IRS) in response to Notice 2024-2, the long awaited "grab bag" guidance on various issues related to the SECURE 2.0 Act changes to the Internal Revenue Code (the "Code"). The Notice, in Q...

On February 15, 2024, ICI filed a comment letter in response to notices published by the Securities and Exchange Commission (SEC) soliciting comments on proposed rule changes filed, pursuant to Exchange Act Rule 19b-4, by the Financial Industry Regulatory Authority (FINRA) and the...

On January 17, 2024, Investment Company Institute (ICI) submitted comments to the Commodity Futures Trading Commission (CFTC) regarding its proposed amendments to Regulation 1.25 under the Commodity Exchange Act (CEA), which specifies permitted investments ("Permitted Investments") by...

ICI has filed two letters in response to the joint notice of proposed rulemaking issued by the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) to amend the...

ICI has filed two letters in response to the joint notice of proposed rulemaking issued by the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) to amend the...

On December 22, 2023, the Investment Company Institute (ICI) and ICI Southwest submitted a joint comment letter to the Securities and Exchange Commission (SEC) to express concerns with the SEC’s proposal relating to outsourcing investment advisers, which could lead to undue disruption...