Policy Priorities

Comment Letters

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Comment Letter

ICI Global Comment Letter on Financial Resources and Tools for Central Counterparty Resolution

On November 20, 2023, ICI Global filed comments with the Financial Stability Board (FSB) regarding...
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Comment Letter

ICI Global Response to Central Bank of Ireland Discussion Paper

On November 15, 2023, ICI Global filed comments with the Central Bank of Ireland (CBI) regarding the...
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Comment Letter

ICI Comment Letter to the Department of Treasury on the 30-Day Notice

The Investment Company Institute (“ICI”) submitted this comment letter in response to the 30-day...
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Comment Letter

ICI Comment Letter to IRS on New Roth Catch-Up Requirement Under SECURE 2.0 Act

On October 24, 2023, ICI submitted the attached comment letter to IRS and Treasury in response to...
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Comment Letter

ICI Comment Letter on Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Partic...

On October 10, ICI filed a comment letter with the CFTC on its proposed amendments to margin...
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Comment Letter

ICI Comment Letter with SEC on Predictive Data Analytics Proposal

On July 26, 2023, the SEC proposed new rules (the "Proposal") that would require broker-dealers and...
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Comment Letter

ICI Global Responds to Proposed UK Voluntary Code of Conduct for ESG Ratings and Data Providers

On October 4, 2023, ICI Global submitted a response to the consultation launched by the ESG Data and...
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Comment Letter

ICI Comment Letter on Provisions Pertaining to US Investments in Certain National Security Technolog...

In early August, President Biden issued an Executive Order on "Addressing United States Investments...
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Comment Letter

ICI Comment Letter on SEC's Safeguarding Advisory Client Assets Proposal

On September 12, 2023, ICI, along with 25 other trade associations, filed a supplemental joint...
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