Operations and Technology Content

By Electronic Delivery June 4, 2015 Hon. William Wilkins Chief Counsel Internal Revenue Service 1111 Constitution Avenue, NW Washington, DC 20224 RE: Money Market Fund Reform – Adviser Contributions Dear Mr. Wilkins: The Investment Company Institute,1 on behalf of its members, seeks...

May 29, 2015 Secretariat of the Financial Stability Board c/o Bank for International Settlements CH-4002 Basel, Switzerland Re: Consultative Document (2nd); Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important Financial Institutions: Proposed...

March 25, 2015 Financial Stability Oversight Council Attn: Patrick Pinschmidt Deputy Assistant Secretary for the Financial Stability Oversight Council 1500 Pennsylvania Avenue NW Washington, DC 20220 Re: Notice Seeking Comment on Asset Management Products and Activities (FSOC-2014...

November 3, 2014 Ms. Phoebe W. Brown Secretary Public Company Accounting Oversight Board 1666 K Street, N.W. Washington, DC 20006-2803 Re: Staff Consultation Paper, Auditing Accounting Estimates and Fair Value Measurements Dear Ms. Brown: The Independent Directors Council and the...

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1  ICI Global Response to MiFID/MiFIR ESMA Consultation Section 2.15 – Legitimacy of inducements to be paid to/by a third person Q79. Do you agree with the proposed exhaustive list of minor non-monetary benefits that are acceptable? Should any other benefits be included on the list...

June 16, 2014 Marcia E. Asquith Office of the Corporate Secretary FINRA 1735 K Street, NW Washington, DC 20006-1506 Re: BrokerCheck, FINRA Notice 14-19 (April 2014) Dear Ms. Asquith: The Investment Company Institute1 appreciates the opportunity to comment on FINRA’s proposed amendment...

May 23, 2014 Marcia E. Asquith Office of the Corporate Secretary FINRA 1735 K Street, NW Washington, DC 20006-1506 Re: Retrospective Rule Review, FINRA Notice 14-15 (April 2014) Dear Ms. Asquith: The Investment Company Institute1 appreciates the opportunity to comment on FINRA Rule...

ICI: G-SIFI Designation of Regulated Funds Unnecessary and Inappropriate, Would Harm Investors FSB Focus on Size Alone Misplaced; Leverage Is Critical in Determining Risk Washington, DC, April 8, 2014 - Designation of regulated funds like US mutual funds as “global systemically...

April 7, 2014 Secretariat of the Financial Stability Board c/o Bank for International Settlements CH-4002 Basel, Switzerland Re: Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important Financial Institutions: Proposed High-Level Framework and...