TAILIEUCHUNG - Strengthening Oversight and Regulation of Shadow Banking: A Policy Framework for Oversight and Regulation of Shadow Banking Entities

The Investment Company Institute (“ICI”) and ICI Global appreciate the opportunity to comment on the consultative document published by the Financial Stability Board (“FSB”) entitled “Strengthening Oversight and Regulation of Shadow Banking: A Policy Framework for Oversight and Regulation of Shadow Banking Entities.”1 ICI is the national association of . investment companies, including mutual funds, closedend funds, exchange-traded funds (“ETFs”), and unit investment trusts (“UITs”) registered under the Investment Company Act of 1940 (“Investment Company Act”).2 ICI seeks to encourage adherence to high ethical standards, promote public understanding, and otherwise advance the interests of . registered funds, their shareholders, directors, and advisers. ICI Global is the global association. | Global INVESTMENT COMPANY INSTITUTE 1401 H Street NW Washington DC 20005-2148 USA 202 326-5800 35 New Broad street London EC2M 1NH UK 44 o 203 009 3100 January 14 2013 Via email fsb@ Secretariat of the Financial Stability Board c o Bank for International Settlements CH-4002 Basel Switzerland Re Strengthening Oversight and Regulation of Shadow Banking A Policy Framework for Oversight and Regulation of Shadow Banking Entities Dear Sir or Madam The Investment Company Institute ICI and ICI Global appreciate the opportunity to comment on the consultative document published by the Financial Stability Board FSB entitled Strengthening Oversight and Regulation of Shadow Banking A Policy Framework for Oversight and Regulation of Shadow Banking Entities. 1 ICI is the national association of . investment companies including mutual funds closed-end funds exchange-traded funds ETFs and unit investment trusts UITs registered under the Investment Company Act of 1940 Investment Company Act .2 ICI seeks to encourage adherence to high ethical standards promote public understanding and otherwise advance the interests of . registered funds their shareholders directors and advisers. ICI Global is the global association of regulated funds publicly offered to investors in leading jurisdictions worldwide. ICI Global seeks to advance the common interests and promote public understanding of global investment funds their managers and investors. As ofJanuary 2013 members of ICI and ICI Global collectively manage total assets of over . trillion. 1 Financial Stability Board Strengthening Oversight and Regulation of Shadow Banking A Policy Frameworkfor Oversight and Regulation of Shadow Banking Entities November 18 2012 available at http publications r Consultative Document . 2 The remainder of this letter uses the term . registered funds to refer to all of such funds collectively unless the context

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