Fund Regulation
Broker-Dealer & Principal Underwriter Issues
ICI Comment Letter to CFTC and SEC on Portfolio Margining (pdf)
ICI Comment Letter on SEC Proposed Exemptive Order on Portfolio Margining (pdf)
Focus on Funds: Funds Step Up Fight Against Elder Abuse and Fraud
June 19, 2020—As the global coronavirus pandemic has made some fund investors more vulnerable to...
Commodities
ICI Comment Letter on CFTC Request for Comment on Swap Clearing Requirements and LIBOR Transition (pdf)
ICI Files Comment Letter with CFTC on "Project KISS" (pdf)
ICI Files Comment Letter on CFTC Recordkeeping Proposal (pdf)
ICI Files Comment Letter on CFTC Proposal to Amend Recordkeeping Requirements for DCM and SEF Members (pdf)
Cybersecurity
ICI Comment Letter on Proposed CIP Rule for Advisers
In this letter, ICI provides comments on the notice of proposed rulemaking that would require...
ICI Comment Letter on the CIRCIA Proposal
July 3, 2024— in this letter ICI provides its views on the notice of proposed rulemaking on Cyber...
ICI Supplemental Comment Letter on Regulation S-P, Cybersecurity for Broker-Dealers and Investment Advisers
In the April Commission Statement Relating to Certain Administrative Adjudications and the Second...
Derivatives
ICI Comment Letter to CFTC and SEC on Portfolio Margining (pdf)
ICI Comment Letter on SEC Proposed Exemptive Order on Portfolio Margining (pdf)
ICI Applauds SEC’s Final Derivatives Rule
ICI Applauds SEC’s Final Derivatives Rule Rule Provides Clarity on Use of Derivatives Washington, DC...
Disclosure
Financing a US Transition to a Sustainable Low-Carbon Economy (pdf)
ICI Recommends Ways SEC Can Further Modernize Fund Disclosure and Improve the Investor Experience
A modern fund disclosure system should provide investors with digestible, layered information...
ICI President and CEO Eric J. Pan Letter to SEC Chairman Jay Clayton on Disclosure Reforms (pdf)
Electronic Delivery
ICI Supplemental Letter to SEC on E-delivery (pdf)
ICI Applauds Approval of Labor Department E-Delivery Rule
ICI Applauds Approval of Labor Department E-Delivery Rule Rule Will Make Disclosures and...
Focus on Funds: 401(k) Disclosure Rules Meet the Modern Age
Focus on Funds 401(k) Disclosure Rules Meet the Modern Age For the first time since smartphones...
Enforcement Actions
Focus on Funds: SEC Has Ambitious Agenda for Funds
U.S. Securities and Exchange Commission Chair Mary Jo White laid out a list of SEC priorities in her...
IDC Comment Letter on SEC's Proposal To Permit General Solicitation and General Advertising By Privately Offered Funds (pdf)
ICI Comments on Proposed Rules to Implement the JOBS Act (pdf)
ESG Issues
ICI Response to Proposed Hong Kong Voluntary Code of Conduct for ESG Ratings and Data Providers
ICI submitted a response to the consultation launched by the Hong Kong ESG Ratings and Data Products...
June 21, 2024
Memo #35742
ICI Responds to Proposed Hong Kong Voluntary Code of Conduct for ESG Ratings and Data Providers
ICI submitted a response to the consultation launched by the Hong Kong ESG Ratings and Data Products Providers Voluntary Code of Conduct Working Group, sponsored by the Securities and Futures Commission on a draft voluntary code of conduct for ESG ratings and...
Joint Comment Letter on Effect of Stay of Public Company Climate Rule on Fund and Adviser ESG Proposal
On April 8, 2024, the Investment Company Institute (ICI) and ICI Southwest submitted a supplemental...
Fees
ICI Letter to SEC on SR-NYSE-2020-96 Regarding FINRA Oversight of Processing Fees (pdf)
ICI Comment Letter Supporting SEC's Proposed Rescission of Effective-Upon-Filing Procedure for NMS Plan Fee Amendments (pdf)
ICI Comment Letter on Processing Fees Charged by Intermediaries for Distributing Materials Other Than Proxy Materials to Fund Investors (pdf)
Financial Stability
Regulated Funds: Supporting the Economy During the COVID-19 Crisis
In a recent call with the Financial Stability Board, ICI President and CEO Paul Schott Stevens...
Financial Stability Board COVID-19 Trade Association Call
Financial Stability Board COVID-19 Trade Association Call Paul Schott Stevens President and CEO...
FSOC’s Proposals Would Promote Financial Stability, Not Undermine It
FSOC’s Proposals Would Promote Financial Stability, Not Undermine It By Paul Schott Stevens (As...
Financial Services Regulatory Reform
Joint Comment Letter on Request to Extend Review of FINRA Securities Loan Reporting and Dissemination Proposal
The Investment Company Institute, the Canadian Securities Lending Association, the International...
UK FCA Discussion Paper on Financial Services Compensation Scheme - ICI Global Response (pdf)
ICI Global Letter Regarding SEBI Circular Introducing T+1 Rolling Settlement (pdf)
Fixed-Income Securities
ICI Files Comment Letter with OCC on Proposal Regarding Stays in Qualified Financial Contracts of Certain OCC-Regulated Banks (pdf)
ICI Submits Comment Letter to SEC on Proposed FINRA Rule Change Relating to the Reporting of U.S. Treasury Securities to TRACE (pdf)
ICI Files Comment Letter on Application of Risk Retention Proposal to Third-Party Tender Options Bond Structure (pdf)
International
ICI Global Response to EU Consultation on Disclosure Regulation RTS (pdf)
Focus on Funds: Landmark European Financial Regulation Faces Reform
July 24, 2020—Regulators in the European Union are planning changes to MiFID that could affect...
ICI Response to ESMA Liquidity Management Tools Consultation
October 8, 2024—ICI filed a response to the European Securities and Markets Authority’s...
Investment Advisers
ICI Applauds Introduction of the "Expanding Investment Opportunities Act"
ICI Applauds Introduction of the “Expanding Investment Opportunities Act” Legislation Would Help...
ICI Joins IAA in Letter to Nevada on Fiduciary Duty Rules (pdf)
Focus on Funds: How the Fund Industry Is Adapting to Trends in Distribution
Focus on Funds How the Fund Industry Is Adapting to Trends in Distribution Financial advisers and...
Municipal Securities
ICI Files Comment Letter Opposing MSRB Plan to Impose a Fee on Underwriters of 529 Plans (pdf)
ICI Comment Letter on SEC's Proposal to Enhance Disclosure Regarding Municipal Securities (pdf)
ICI Submits Comment Letter to MSRB Supporting Its Concept Proposal to Improve Disclosure of Direct Purchases and Bank Loans
Products
ICI and ICI Global Comment Letter to ESMA's Call for Evidence
On December 15, 2023, ICI and ICI Global filed a cover note and response to the European Securities...
Fixing Our Broken Proxy Voting System
November 15, 2024—Just as publicly traded companies do, mutual funds, ETFs, and closed-end funds...
Investment Company Institute Unveils New Logo
May 23, 2024—Today, ICI unveiled its new logo at its Leadership Summit in Washington, DC, marking...
Risk Management
Financing a US Transition to a Sustainable Low-Carbon Economy (pdf)
Focus on Funds: ICI Leads Effort to Help Funds Modernize Interval Fund Operations
Regulators and investors alike are taking a new look at interval funds, and ICI has responded by...
Focus on Funds: US Liquidity Management Rules Draw Global Interest
Focus on Funds US Liquidity Management Rules Draw Global Interest The US Securities and Exchange...
State Issues
ACLI, The Credit Roundtable, ICI, IIF, and LICONY Oppose New York Legislature Bills on Sovereign Debt
Proposed legislation would have unintended consequences for emerging economies, investors and state...
ICI Submits Opposition Letter to NY Stock Transfer Tax (STT) (pdf)
ICI Submits Opposition Letter to NJ FTT Proposal (pdf)
Valuation
ICI and IDC Welcome SEC’s Efforts to Modernize Framework for Fund Valuation Practices
ICI and IDC Welcome SEC’s Efforts to Modernize Framework for Fund Valuation Practices Washington, DC...