Comment Letter Content

On November 15, 2023, ICI Global filed comments with the Central Bank of Ireland (CBI) regarding the Discussion Paper: An approach to macroprudential policy for investment funds (Discussion Paper). In the Discussion Paper, the CBI presents its assessment of the systemic risks...

The Investment Company Institute (“ICI”) submitted this comment letter in response to the 30-day notice (“Notice”) issued by the Department of Treasury (“Treasury”), on behalf of the Financial Crimes Enforcement Network (“FinCEN”), for the beneficial ownership information (“BOI”)...

On October 24, 2023, ICI submitted the attached comment letter to IRS and Treasury in response to IRS Notice 2023-62. Notice 2023-62, issued August 25, 2023, effectively provides for a 2-year delay (until taxable years beginning after December 31, 2025) of the applicability of section...

On October 10, ICI filed a comment letter with the CFTC on its proposed amendments to margin requirements for uncleared swaps related to the treatment of seeded funds and eligibility of certain money market funds (MMFs) as eligible collateral. The letter expresses support for...

On July 26, 2023, the SEC proposed new rules (the "Proposal") that would require broker-dealers and investment advisers (collectively, "firms") to take certain steps to address conflicts of interest associated with their use of predictive data analytics (PDA) and similar technologies...

On October 4, 2023, ICI Global submitted a response to the consultation launched by the ESG Data and Ratings Working Group (DRWG), convened by the UK Financial Conduct Authority (FCA), on a draft voluntary code of conduct for ESG ratings and data providers. The voluntary code of...

In early August, President Biden issued an Executive Order on "Addressing United States Investments in Certain National Security Technologies and Products of Countries of Concern." That same day Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) regarding the...

On September 12, 2023, ICI, along with 25 other trade associations, filed a supplemental joint comment letter (Joint Letter) with the SEC urging the Commission not to adopt the Proposal in its current form. The Joint Letter further urges the Commission to gain a better understanding...

On October 10, ICI filed a comment letter with the Securities and Exchange Commission (SEC or "Commission") on its proposal regarding conflicts of interest associated with the use of predictive data analytics (PDA) and other "covered technologies" by broker-dealers and investment...

ICI Global submitted a letter to the Financial Stability Board’s (FSB) invitation for feedback from stakeholders as part of the Peer Review on Money Market Fund (MMF) Reforms. ICI Global and its members are committed to working with international policymakers, including through the...