Research
      
    
    Summary of Recent ICI Research on First-Mover Advantage, Dilution, and Systemic Risk in Open-End Fun...
      
        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...
      
    
      
        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...
      
    
      
        Comment Letter