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ICI Comment Letter on NYDFS Industry Guidance Proposal

The Investment Company Institute (“ICI”) submitted this comment on the Industry Guidance (the “Guidance”) proposed by the New York Department of Financial Services (“NYDFS”) regarding the presumption of control that applies to both New York chartered depository institutions (“Banking...
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ICI Comment Letter on the SEC's Rule 14a-8 Proposal

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...
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ICI Comment Letter on SEC ESG Disclosure Proposal

On August 16, 2022, ICI submitted a comment letter on the SEC's proposal for new disclosure requirements for investment companies and investment advisers. The letter expresses ICI's support for the fundamental goals of the Commission's proposal: to mitigate the risk of greenwashing...
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IDC Comment Letter on Investment Company Names Rule Proposal

The Independent Directors Council appreciates the opportunity to comment on the Securities and Exchange Commission’s proposal to amend Rule 35d-1 under the Investment Company Act of 1940 (the “Names Rule”). The proposal seeks to expand the universe of funds that are required to adopt...
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The Future of Regulated Funds: Modernizing the ’40 Act

I’m sure you noticed that we’ve renamed this conference. What used to be called the “Mutual Funds and Investment Management Conference” is now simply the “Investment Management Conference.” This change reflects a simple reality. While mutual funds still comprise the bulk of our...