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Comment Letter

ICI Comment Letter on FINRA’s and MSRB’s Filings with the SEC to Shorten Reporting Timeframes

On February 15, 2024, ICI filed a comment letter in response to notices published by the Securities...
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Comment Letter

ICI Comment Letter on Regulatory Capital Rule: Large Banking Organizations and Banking Organizations...

ICI has filed two letters in response to the joint notice of proposed rulemaking issued by the Board...
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Comment Letter

ICI Supplemental Comment Letter on Regulatory Capital Rule: Large Banking Organizations and Banking ...

ICI has filed two letters in response to the joint notice of proposed rulemaking issued by the Board...
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Comment Letter

ICI Comment Letter on SEC Treasury Clearing Proposal

On December 23, ICI filed a comment letter with the Securities and Exchange Commission on its...
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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...
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Comment Letter

ICI Files Comment Letter with OCC on Proposal Regarding Stays in Qualified Financial Contracts of Ce...

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Comment Letter

ICI Submits Comment Letter to SEC on Proposed FINRA Rule Change Relating to the Reporting of U.S. Tr...

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ICI Viewpoints

The “Waterfall Theory” of Liquidity Management Doesn’t Hold Water

In a series of recent blog posts, economists at the Federal Reserve Bank of New York have discussed...
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Comment Letter

ICI Files Comment Letter on Application of Risk Retention Proposal to Third-Party Tender Options Bon...