ICI Asks SEC to Consider Aggregate Impact of its Rulemakings

The Investment Company Institute ("ICI") urged the SEC to reconsider its proposed rulemaking in several areas, arguing that the aggregate impact of "significant deficiencies" in the "interconnected" rulemakings are likely to have negative impacts on regulated investment funds.

In a supplement to comment letters on numerous SEC proposals, the ICI explained that there was a "need to account for the aggregated impact of the Commission’s rulemakings." Further, the ICI challenged the SEC’s ability to properly assess market functionality and effects on market participants and contended that, by pushing through numerous substantive rulemakings in a condensed period of time, the SEC has created the potential to "irreparably harm investors and the markets." ICI requested that the SEC address deficiencies in the proposed rulemakings by:

• publishing a thorough analysis of the proposals’ cumulative impact that accounts for their interconnections and dependencies;
• reopening the comment period for each rule in order for market participants to "understand and assess holistically the [SEC’s] proposals"; and
• finalizing the rules, after "appropriate analysis and public comment," holistically rather than one at a time or in an isolated series.