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Statement of Investment Company Institute to ERISA Advisory Council on Permissive Transfers of Uncashed Checks from ERISA Plans to State Unclaimed Property Funds (PDF)

15 pages. "[ICI believes that] expansion of the PBGC program generally offers a more optimal solution to the issue of missing participants, including the problems associated with uncashed distribution checks.  Until the adoption of that inter-agency solution ... [ICI] recommend[s] that the [DOL] issue guidance facilitating the use of state unclaimed property funds as one of several permissible options for the handling of uncashed distribution checks[.]"

Investment Company Institute Comment Letter to IRS on Proposed Required Minimum Distribution Exception for Longevity Annuity Contracts (PDF)

"[ICI does] not believe it would be appropriate to expand the exclusion beyond strict longevity insurance, within the parameters outlined in the proposal. [The ICI's] comments also include some general concerns relating to incentivizing the use of annuities."

Investment Company Institute Comment Letter to DOL on Proposed Regs Defining 'Employer' Under Section 3(5) of ERISA (PDF)

10 pages. "[ICI urges] the Department to interpret the definition of employer more broadly, specifically by expanding the category of persons able to act indirectly in the interest of employers ... Any concerns the Department may have with respect to permitting MEP sponsorship by financial services firms can be mitigated by using established methods for ensuring both the legitimacy and qualifications of the MEP sponsor and protection from conflicts of interest. Failure to expand the interpretation as recommended likely will result in market distortions and inefficiencies, to the detriment of retirement savers."

Investment Company Institute Comment Letter to Senate HELP Committee Hearing on 'Pension Savings: Are Workers Saving Enough for Retirement?' (PDF)

"[T]his Committee should be mindful that the first, and most important, principle to follow in the context of its activities is: do no harm.... [ICI urges] this Committee to avoid any actions that would impair the ability of the voluntary employer-provided retirement system to provide Americans with retirement resources ... The composition of resources relied upon in retirement will differ from household to household ... The shift in private-sector retirement plans from predominantly [DB] plans to predominantly [DC] plans is unlikely to reduce retirement preparedness."

Investment Company Institute Comments on SEC's Proposed New 12b-1 Rule (PDF)

32 pages. ICI outlines specific comments, concerns, and recommendations on five major elements of the proposal: ongoing sales charges; marketing and service fees; board oversight; new disclosures; and the proposed exemption from Section 22(d) that would allow for a new distribution option.

2010 Investment Company Fact Book from Investment Company Institute (PDF)

Excerpt: ICI's annual compilation -- our fiftieth edition -- reports on retirement assets, characteristics of mutual fund owners, use of index funds, and other trends.

Investment Company Institute Comment Letter to SEC on the Results of Investor Testing Regarding Target Date Funds in Connection with the Target Date Retirement Fund Names and Marketing Proposal (PDF)

"The Institute strongly supports the spirit and core of the Commission's Proposal that focuses on communicating key pieces of information about target date funds to investors and requires a prominent table, chart, or graph ('glide path illustration') to convey the idea of the changing asset allocation of the target date fund over the entire life of the fund, including at the target date and the point where the fund arrives at its final asset allocation. The Institute opposes, however, as unnecessary and potentially confusing to investors, a proposed requirement that a target date fund disclose, immediately adjacent to the first use of the fund's name, the fund's asset allocation at the target date ('tagline disclosure')."

Brief of Investment Company Institute as Amicus Curiae in Appeal of 401(k) Fee Case (PDF)

The Plaintiffs in this action contend, inter alia, that decisions tomake certain investment options available to participants in the Edison401(k) plan violated the fiduciaries' duty of prudence under ERISA.Plaintiffs specifically contend that so-called 'retail' mutual fundsoffered by the Plan and the Plan's Money Market Fund would not havebeen offered by a prudent fiduciary. These contentions disregard theneeds of defined contribution plans and important facts about thesetypes of investment options.

Testimony of Investment Company Institute to ERISA Advisory Council on Lifetime Income Solutions as a QDIA (PDF)

45 pages. "Part I of this testimony focuses on research that can shed light on the Council's underlying premise that Americans are under-annuitized and that promoting annuities in DC plans is a necessary policy initiative. To address these issues, this testimony provides a review of the research on the question of annuitization ... Part II of this testimony examines two ideas that have been heavily promoted by proponents of increased annuitization in DC plans: a proposal to modify the [Qualified Default Investment Alternative (QDIA)] safe harbor to permit limits on rights of transferability ... and a proposal to require benefit statements to include a lifetime income illustration based on an annuity calculation. Part II also considers whether implementing the ideas would serve the interests of plan participants and beneficiaries."

Investment Company Institute Supplemental Comment Letter to EBSA on Proposed Fiduciary Definition and Conflict of Interest Rules (PDF)

"This supplemental letter explains why the asset-weighted average return for categories of mutual funds, rather than the simple average, is the appropriate measure for assessing the overall experience of investors using broker-sold funds.... We also provide additional detail about why a large share of IRA investors will not be able to get access to fee-based advice under the Department's proposed rules, even if those advisers also manage taxable investable assets on behalf of these households."