Risk Oversight Content

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...

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 July 18, the Central Bank of Ireland (CBI) published a discussion paper entitled "An approach to macroprudential policy for investment funds" (Discussion Paper). The CBI is accepting comments until November 15.

On 5 July, the Financial Stability Board (FSB) and International Organization of Securities Commissions (IOSCO) each published consultations on liquidity risk management in open-ended funds (OEFs). The FSB and IOSCO are accepting feedback on the consultations by 4 September.

Earlier this month, ICI joined several other trade associations in a letter to the SEC addressing whether certain syndicated loans are securities. In Kirschner v. JP Morgan Chase Bank, N.A. et al. (2d Cir., No. 21-2726), the Second Circuit Court of Appeals is considering that question...

At ICI's 2023 Leadership Summit, SEC Chair Gensler delivered remarks which focused on fund dilution and liquidity and how it relates to financial stability, outstanding SEC rule proposals related to money market funds and liquidity risk management, hard close, and swing pricing, and...

On December 23, 2022, the ICI filed a comment letter with the Securities and Exchange Commission on its proposal entitled "Outsourcing by Investment Advisers." The SEC has proposed a new rule, Rule 206(4)-11, under the Investment Advisers Act of 1940 (the "Advisers Act"), that would...