Comment Letter Content

On September 2, 2023, ICI Global provided comments on the International Organization of Securities Commission’s (IOSCO) consultation on proposed Liquidity Management Tool (LMT) Guidance for Open-Ended Funds (OEFs). Our members help millions of retail investors around the world by...

On September 2, 2023, ICI Global filed comments with the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) regarding their recent Consultations on liquidity risk management in open-ended funds (OEFs). Read more in the comment letter.

On August 23, 2023, ICI submitted a comment letter (Letter) to the IRS and Treasury addressing SECURE 2.0 Act section 305, which amends the Employee Plans Compliance Resolution System (EPCRS), and IRS Notice 2023-43, which provides interim guidance under section 305. The Letter, which...

ICI Global welcomes the changes to the ELTIF primary legislation. Market experience has shown that the initial framework was too onerous and restrictive. Only a few ELTIFs were launched, despite investor demand for vehicles that generate exposure to long-term investments. The...

ICI Global appreciates the opportunity to provide feedback on the Monetary Authority of Singapore (MAS) consultation on a proposed voluntary industry code of conduct for providers of ESG ratings and data products (“Consultation Paper”). ICI Global carries out the international work of...

On August 21, 2023, ICI submitted a response to the Financial Stability Board's consultation, Enhancing Third-Party Risk Management and Oversight. ICI's letter expresses general support for the overall goals and approach of the FSB's consultation and its use of a toolkit, rather than...

ICI recently submitted this letter to the SEC noting that it has issued a wide range of interconnected rule proposals (the "Interconnected Rules") over the last two-and-a-half years but has failed to consider and analyze the Interconnected Rules holistically. We pointed out that, in...

On behalf of our members, we request that the Securities and Exchange Commission (the “Commission”) extend the comment period to the above-referenced proposed rules (the “Proposal”) for an additional 60 days. Collectively, our associations represent a wide range of market participants...

On August 7, 2023, the Investment Company Institute and Independent Directors Council filed a joint comment letter in response to the Public Company Accounting Oversight Board's (PCAOB) proposed amendments to the auditing standards related to a company's noncompliance with laws and...

On July 31, ICI submitted a letter supplementing our comments on the SEC's proposed amendments ("Proposal") to Rule 35d-1 ("Names Rule") under the Investment Company Act of 1940 ("1940 Act"). In the letter, we point out that regulatory processes and requirements already exist to...