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Comment Letter

ICI Supplemental Comment Letter on the SEC’s 2020 Disclosure Proposal Related to Performance Benchma...

Earlier this week, ICI submitted supplemental comments (linked below) on the SEC's 2020 disclosure...
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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

Joint Comment Letter Responding to PRA/FCA Consultation

On October 3, ICI co-signed a letter with several associations (the Associations) in response to a...
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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

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 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...