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Committee: Investment Management Regulation

Letter to the SEC commenting on proposed amendments to remove references to credit ratings of nationally recognized statistical rating organizations (October 2014) ( PDF format )
Subject area: Credit Ratings

Letter to the SEC regarding Money Market Fund Reform, Amendments to Form PF, SEC Release No. 33-9408 (September 2013) ( PDF format )
Subject area: Money Market Mutual Funds

Letter to the Commodity Futures Trading Commission offering comments on the proposing release Harmonization of Compliance Obligations for Registered Investment Companies Required to Register as Commodity Pool Operators (May 2012) ( PDF format )
Subject area: Commodity Pool Operators

Letter to the SEC on File No. S7-35-11 Treatment of Asset Backed Issuers under the Investment Company Act (November 2011) ( PDF format )
Subject area: Investment Securities

Letter to the SEC regarding Release IC-29592 which would remove references to credit ratings in Rules 2a-7 and 5b-3 under the Investment Company Act of 1940 (April 2011) ( PDF format )
Subject area: Credit Ratings

Letter to the SEC regarding proposed rule (File No. S7-15-10) on Mutual Fund Distribution Fees (November 2010) ( PDF format )
Subject area: Mutual Funds

Letter to the SEC regarding proposed rule (File No. S7-11-09) on money market fund reform (September 2009) ( PDF format )
Subject area: Money Markets

Letter to the SEC commenting on File No. S7-18-09 - Political Contributions by Certain Investment Advisers (October 2009) ( PDF format )
Subject area: Pay to Play

Letter to the SEC commenting on an array of current issues relevant to the investment management industry (February 2009) ( PDF format )
Subject area: Investment Management Regulation

Comments on the SEC proposed guidance regarding the duties and responsibilities of Investment Company Boards of Directors with Respect to Investment Adviser Portfolio Trading Practices (October 2008) ( PDF format )
Subject area: Investment Companies

Letter to the SEC offering comments to the proposed amendments which seek to enhance the disclosure provided to investors in registered open-end management investment companies ( PDF format )
Subject area: Summary Prospectus

Letter to the SEC commenting on proposed recommendations to alleviate unnecessary burdens on independent directors of investment companies registered under the Investment Company Act of 1940 ( PDF format )
Subject area: Independent Directors

Letter to the SEC setting forth a proposed policy and a set of procedures which would reasonably ensure the proper retention of e-mail containing Rule 204-2 information. ( PDF format )
Subject area: Investment Advisers

Letter to the SEC urging them to file an amicus brief in the case of J. & W. Seligman & Co. Incorporated v. Eliot Spitzer in order to articulate the scope of state regulators' authority under the ICA and the National Securities Markets Improvement Act of 1996 (NSMIA)to investigate and litigate advisory fee issues. ( PDF format )
Subject area: Advisory Fees

Letter to SEC Requesting Guidance re: Retention and Production of e-mail by Investment Advisers ( PDF format )
Subject area: Investment Advisers

Letter to the SEC Regarding Independent Directors of Investment Companies ( PDF format )
Subject area: Investment Companies

Letter to the SEC Regarding Investment Company Governance ( PDF format )
Subject area: Investment Companies

Comments on Section 302 of the Sarbanes-Oxley Act of 2002 - Certification of Disclosure in Companies' Quarterly and Annual Reports ( PDF format )
Subject area: Sarbanes-Oxley Act

Comments to the SEC on the Certified Shareholder Report to be Filed on Proposed Form N-CSR, the Scope of the Certification Requirement, the Uniform Application of the Certification Requirement and the Disclosure Controls and Procedures Mandated Thereby ( PDF format )
Subject area: Sarbanes-Oxley Act

Comments on Sections 404, 406 and 407 of the Sarbanes-Oxley Act of 2002 - Disclosure Required in Companiesí Quarterly and Annual Reports ( PDF format )
Subject area: Sarbanes-Oxley Act

Comments on Section 307 of the Sarbanes-Oxley Act of 2002 ( PDF format )
Subject area: Professional Responsibility

Comments on Section 307 of the Sarbanes-Oxley Act of 2002-Additional Comments by the Committee on Investment Management Regulation ( PDF format )
Subject area: Sarbanes-Oxley Act