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ICI Default BG
Memo#
33831

SEC Reopens Comment Period on Its 2015 Clawback Proposal

Last week, the SEC reopened the comment period for its 2015 clawback proposal, which it never adopted. This will allow further opportunity to analyze and comment on the proposal in light of developments since its publication.
ICI Default BG
Memo#
33750

ICI Files Comment Letter to SEC on Consolidated Audit Trail Funding Model

ICI has filed a comment letter with the SEC on the proposed amendment to the Consolidated Audit Trail National Market System Plan ("CAT NMS Plan") to revise the CAT funding model. ICI recommends that the SEC disapprove the proposed amendment and encourage the SROs to work with...
ICI Default BG
Memo#
33572

President Biden Issues Executive Order on China; Member Call on June 8

On June 3, 2021, President Biden signed a new Executive Order Addressing the Threat from Securities Investments that Finance Certain Companies of the People's Republic of China (EO) and the Office of Foreign Assets Control (OFAC) published a number of new FAQs and updated others...
ICI Default BG
Memo#
33540

China EO 13959: OFAC Issues General License 1B

On May 18, the Office of Foreign Assets Control (OFAC) issued General License 1B "Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies"[1] with respect to Executive Order 13959 of November 12, 2020, Addressing the Threat From Securities...
ICI Default BG
Memo#
33394

Form of Fund of Funds Agreement for Compliance with Rule 12d1-4

To assist funds in implementing new Rule 12d1-4 under the Investment Company Act of 1940, attached are two sample form of Fund of Funds Investment Agreements that can be used between acquiring funds and acquired funds. One version of the form contains footnotes while the other version...