Policy Priorities: Fund Regulation

Advertising

ICI Comment Letter on FINRA’s Proposed Amendments to Communications with the Public Rules (pdf)

ICI Comment Letter on FINRA's BrokerCheck Proposal (pdf)

ICI Comment Letter in Response to DOL's Request for Comment on Its Target Date Fund Disclosure Proposal (pdf)

Broker-Dealer & Principal Underwriter Issues

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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)

Compliance

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Comment Letter on Remuneration Aspects of FCA's DP20/2: Prudential Requirements for MiFID Investment Firms (pdf)

Financial Intermediary Controls and Compliance Assessment Engagements (pdf)

ICI Files Comment Letter with CFTC Supporting Prohibition on Post-Trade Name Give-Up (pdf)

Cybersecurity

ICI Cyber Industry Tabletop Exercise 2024: After-Action Report

The asset management industry faces an escalating battle against cybercriminals employing...

ICI Comment Letter on the Format for Incident Reporting Exchange

December 18, 2024—ICI submitted a Comment Letter to the Financial Stability Board regarding their...

ICI Comment Letter on Proposed CIP Rule for Advisers

In this letter, ICI provides comments on the notice of proposed rulemaking that would require...

Derivatives

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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

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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

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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 Comment Letter on the Implementation of the California Climate-Disclosure Legislation

March 20, 2025—ICI submitted a letter in response to the California Air Resources Board Information...

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...

Fees

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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

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April 22, 2020

By Paul Schott Stevens

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...

March 25, 2025

Memo #36045

ICI Response to UK FCA Consultation on the Retail Disclosure Framework for Consumer Composite Investments

On March 20 we filed a comment letter with the UK Financial Conduct Authority in response to CP24/30 regarding a new retail disclosure framework for Consumer Composite Investments. The new disclosure framework will apply to both UK and overseas UCITS sold to...