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Comment Letter

IDC Comment Letter on Open-End Fund Liquidity Risk Management Programs and Swing Pricing

The Independent Directors Council submitted this comment letter to the SEC on their proposal to...
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Comment Letter

IDC Comment Letter on SEC's Rule Proposal on Outsourcing by Investment Advisers

The Independent Directors Council (IDC) commented on the Securities and Exchange Commission’s...
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Comment Letter

ICI Comment Letter on SEC Treasury Clearing Proposal

On December 23, ICI filed a comment letter with the Securities and Exchange Commission on its...
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Comment Letter

ICI Follow-Up Letter to SEC on Rule 15c2-11 and Rule 144A Debt Securities

On October 25, ICI submitted the attached follow-up letter to SEC Chair Gary Gensler on the...
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Comment Letter

ICI Comment Letter to CFTC and SEC on CCP Governance and Conflicts of Interest Proposals

ICI filed this comment letter with the CFTC on its DCO governance rule proposal and the SEC on its...
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Comment Letter

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...
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Comment Letter

IDC Comment Letter on Certain Information Providers Acting as Investment Advisers

The Independent Directors Council responded to the Commission’s request for comment regarding...
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Comment Letter

IDC Comment Letter on Investment Company Names Rule Proposal

The Independent Directors Council appreciates the opportunity to comment on the Securities and...
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Comment Letter

ICI Comment Letter on Certain Information Providers Acting as Investment Advisers

In June, the SEC issued a request for comment on index providers, model portfolio providers, and...