Fund Operations Content

On October 13, the Securities and Exchange Commission adopted new Rule 10c-1a ("Final Rule") under the Securities Exchange Act of 1934 ("Exchange Act"), which is intended to increase transparency and efficiency in the securities lending market. We were pleased that the Final Rule was...

On October 10, the SEC adopted final amendments to its rules governing beneficial ownership reporting on Schedules 13D and 13G ("Final Rules"). We are pleased that the Final Rules reflect many of ICI's comments. The Final Rules were approved by the Commission by a 4-1 vote...

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...

The ICI Year-End Reporting Layouts have been modified for improved functionality.

In its August 24, 2023 decision, a three-judge panel of the United States Circuit Court of Appeals for the Second Circuit held in Kirschner v. JP Morgan that notes issued as part of a syndicated term loan transaction ("Notes") were not securities. In doing so, the court applied the...

The SEC recently issued its Safeguarding Advisory Client Assets Proposal (Proposal), which would expand the scope of the current Investment Advisers Act custody rule (Rule 206(4)-2) and impose significant new requirements on qualified custodians and investment advisers that have...

ICI Global has 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). This memorandum summarizes ICI Global's comments.

On September 11, 2023, ICI, along with 13 other trade associations, filed a letter with the Securities and Exchange Commission (SEC or "Commission") raising serious concerns regarding the Commission's recent proposal on conflicts of interest associated with the use of predictive data...