Comment Letter Content

The Investment Company Institute submitted a comment to the Department of Labor (the “Department”) on their proposed regulation defining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income Security Act of 1974 (ERISA), or an individual retirement...

On December 22, 2023, the Investment Company Institute (ICI) and ICI Southwest submitted a joint comment letter to the Securities and Exchange Commission (SEC) on how the SEC’s proposed amendments to the liquidity risk management rule (the “liquidity rule”) would affect mutual funds...

Last month, FINRA filed with the SEC proposed amendments to Rule 2210 (Communications with the Public) (the "rule"). If adopted, the amendments would permit a FINRA member to project the performance or provide a targeted return with respect to a security or asset allocation or other...

ICI Global submitted the attached letter to the Call for Evidence launched by the UK Department for Energy Security and Net Zero on the cost, benefits, and practicalities of Scope 3 greenhouse gas (GHG) emissions reporting in the UK. The UK Government is considering the standards...

ICI Global welcomes the European Commission’s targeted consultation seeking feedback on the implementation of the Sustainable Finance Disclosure Regulation (SFDR), and its focus on improving the disclosure framework. Our mission is to strengthen the foundation of the asset management...

On December 15, 2023, ICI and ICI Global filed a cover note and response to the European Securities Market Authority's (ESMA) call for evidence on shortening the settlement cycle (Call for Evidence).

On December 6, 2023, ICI submitted a letter to the Office of Management and Budget (OMB), expressing significant concerns regarding the substantial proposed changes and the cost-benefit analysis included in the Department of Labor's (DOL) proposed amendments to Prohibited Transaction...

On November 30, 2023, the Investment Company Institute (ICI) and ICI Southwest submitted a joint comment letter to the Securities and Exchange Commission (SEC) on its proposal to require registered investment advisers, registered investment companies, and business development...

The Investment Company Institute and ICI Southwest are writing to express our joint concerns with the SEC’s proposal to (i) amend the liquidity risk management rule (the “liquidity rule”) for mutual funds and ETFs (“funds”) and (ii) mandate that mutual funds impose a “hard close” on...

On November 20, 2023, ICI Global filed comments with the Financial Stability Board (FSB) regarding the Consultation report on Financial Resources and Tools for Central Counterparty Resolution (Consultation). The Consultation presents a summary of the FSB's analysis of the benefits and...