Policy Priorities

Comment Letters

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Comment Letter

ICI Comment Letter to OECD Requesting Clarifications to Asset Manager Exclusion from Pillar One Amou...

ICI submitted this response to the OECD’s Progress Report on Amount A of Pillar One (“Progress...
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Comment Letter

ICI Supplemental Comment Letter on SEC's Proposed Money Market Fund Reforms

On August 8, ICI filed this letter with the Securities and Exchange Commission to supplement our...
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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...
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Comment Letter

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...
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Comment Letter

ICI Comment Letter on Investment Company Names Rule Proposal

At the end of May, the Securities and Exchange Commission proposed amendments to Rule 35d-1 (Names...
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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 Proposed Amendments to NASAA's REIT Guidelines

Last week, ICI filed the attached comment letter on the North American Securities Administrators...
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Comment Letter

ICI Comment Letter to OECD on Pillar One Exclusion for Regulated Financial Services (pdf)

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