Investment Advisers Content

Earlier this week, ICI submitted supplemental comments (linked below) on the SEC's 2020 disclosure proposal for open-end funds ("funds"). On September 15, the SEC's Office of the Investor Advocate filed with the SEC a research paper on funds' choice of performance benchmarks and...

On October 3, 2022, ICI filed a comment letter on behalf of members discussing certain concerns with the proposals that many members had. We filed one letter to both FINRA and MSRB. The FINRA proposal sought comment on reducing the trade reporting timeframe for transactions in TRACE...

In July 2022, the SEC proposed amendments to Rule 14a-8 (the shareholder proposal rule) by a 3-2 vote. The proposal would narrow three bases upon which companies may exclude shareholder proposals from their proxy statements: the “substantial implementation,” “duplication,” and...

On August 19, ICI filed a comment letter discussing member views regarding the issues raised in the US Department of the Treasury ("Treasury") request for information on the possibility of additional post-trade transparency of data for secondary transactions in Treasury securities...

In June, the SEC issued a request for comment on index providers, model portfolio providers, and pricing services. The release poses many questions exploring whether information providers might meet the definition of "investment adviser" under the Investment Advisers Act of 1940...

The Independent Directors Council responded to the Commission’s request for comment regarding whether, under certain circumstances, the activities of index providers, model portfolio providers, and pricing services (Information Providers) warrant investment adviser status. We...

Last week, ICI filed the attached comment letter on the North American Securities Administrators Association's request for comment on proposed amendments to its Statement of Policy Regarding Real Estate Investment Trusts. Although the proposed amendments would apply most directly to...