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The impact assessment concludes that a 'strict liability' standard obliging depositaries to return instruments lost in custody irrespective of fault or negligence is both conducive to ensuring a high level of investor protection and to achieving a uniform standard across the EU. In line with the needs of retail investors, liability in case of the loss of an instrument held in custody should be based on a uniform EU standard that entails a 'strict liability' for returning lost instruments at the cost of the principal custodian, without any option for the principal custodian to discharge liability in case of. | INVESTMENT If I COMPANY l INSTITUTE 1401 H Street NW Washington DC 20005-2148 USA 202 326-5800 www.ici.org May 4 2012 By Electronic Transmission James H. Freis Jr. Director Financial Crimes Enforcement Network U.S. Department of the Treasury P.O. Box 39 Vienna VA 22183 Re Docket Number FINCEN-2012-0001 Dear Mr. Freis The Investment Company Institute ICI 1 appreciates the opportunity to comment on the advance notice of proposed rulemaking issued by the Financial Crimes Enforcement Network FinCEN seeking comment on a wide range of questions relating to the development of an explicit customer due diligence CDD obligation for financial institutions the ANPRM .2 The ANPRM describes FinCEN s concern with the lack of uniformity and consistency in the way financial institutions address CDD and beneficial ownership. FinCEN therefore believes that issuing an express CDD rule including a requirement to obtain beneficial ownership information may be necessary to protect the United States financial system from criminal abuse and to guard against terrorist financing money laundering and other financial crimes. I. Executive Summary The ICI and its members have long supported the government s efforts to combat money laundering activity in the financial services industry and we remain committed to working with FinCEN and the 1 The Investment Company Institute ICI is the national association of U.S. registered investment companies including mutual funds closed-end funds exchange-traded funds ETFs and unit investment trusts UITs . ICI seeks to encourage adherence to high ethical standards promote public understanding and otherwise advance the interests of funds their shareholders directors and advisers. Members of ICI manage total assets of 13.4 trillion and serve over 90 million shareholders. 2 Customer Due Diligence Requirements for Financial Institutions 77 FR 13 046 proposed March 5 2012 available at http www.gpo.gov fdsys pkg FR-2012-03-05 pdf 2012-5187.pdf the ANPRM . Mr. James
