Comment Letters

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ICI Default BG

ICI Comment Letter to the SEC to Expand Its Principles Based Co-Investment Relief

ICI submitted a comment letter to the Securities and Exchange Commission to expand its principles-based co-investment relief, which was first issued in April 2025—to open-end funds, thereby allowing open-end funds to participate in co-investment transactions alongside private funds under the same updated conditions as closed-end funds and business development companies.

ICI Default BG

ICI Comment Letter on Inefficiencies and Costs Obtaining Edgar Codes

ICI submitted a comment letter to highlight operational inefficiencies and costs faced by asset managers when obtaining EDGAR codes for “Affiliated Entities” as part of filing with the Securities and Exchange Commission, in particular as it relates to expanded principles-based co-investment exemptive relief.

ICI Default BG

ICI Comment Letter Supporting the INVEST Act

ICI submitted a comment letter to Speaker of the House Mike Johnson and House Minority Leader Hakeem Jeffries expressing support for H.R. 3383, the Incentivizing New Ventures and Economic Strength Through Capital Formation (INVEST) Act.