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...
Cybersecurity
ICI Comment Letter on SEC's Cybersecurity Risk Management
The Investment Company Institute appreciates the opportunity to provide its comments on the proposal...
Working to Ensure Funds Can Maintain Vital Services
Key personnel of mutual fund sponsors and service providers should be deemed “essential workers” and...
During COVID-19 Crisis, Fund Company Staff Are Essential
As governments consider extending orders to “shelter in place,” they must include staff of fund...
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...
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...
Summary of Recent ICI Research on First-Mover Advantage, Dilution, and Systemic Risk in Open-End Funds (pdf)
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...
ICI Joins Other Trades in Asking IRS for Changes to Draft Forms W-4P and W-4R (pdf)
ICI, SIFMA, and DTCC Leading Effort to Shorten US Securities Settlement Cycle to T+1, Collaborating with the Industry on Next Steps
A shorter settlement cycle will benefit investors and market participant firms by reducing systemic...
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...
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...
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
Investment Company Institute Unveils New Logo
May 23, 2024—Today, ICI unveiled its new logo at its Leadership Summit in Washington, DC, marking...
ICI Comment Letter on CFTC Proposed Revisions to Regulation 1.25
On January 17, 2024, Investment Company Institute (ICI) submitted comments to the Commodity Futures...
ICI Comment Letter on Regulatory Capital Rule: Large Banking Organizations and Banking Organizations with Significant Trading Activity
ICI has filed two letters in response to the joint notice of proposed rulemaking issued by the Board...
Risk Management
Financing a US Transition to a Sustainable Low-Carbon Economy (pdf)
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...
ICI Comment Letter to FSB on Third-Party Risk Management and Oversight
On August 21, 2023, ICI submitted a response to the Financial Stability Board's consultation...
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...