ICI Quarterly Update, April 2026
Investor-Focused Policy Is Taking Shape—and What Comes Next
Across Washington, policymakers are focused on modernizing the regulatory framework in ways that reflect how markets operate today and improve outcomes for investors. That momentum is translating into concrete wins and opportunities ahead.
Nowhere is that more evident than in the growing alignment around private market access. The Department of Labor’s proposal to provide a clearer framework for including a broader range of investments in 401(k) plans is a significant step forward. Combined with ICI’s efforts to expand co-investment relief, these developments point to a practical path for bringing private market exposure into regulated funds.
We are also seeing long-standing priorities gain traction at the SEC. Actions to facilitate ETF share class trading provide the clarity needed to move forward with a more flexible, efficient framework—expanding investor choice while maintaining strong protections.
On fund reporting, the direction is improving. After ICI raised concerns about more frequent and accelerated disclosure under the 2024 Form N-PORT changes, the SEC has proposed a more balanced approach—restoring quarterly public reporting and extending filing timelines, recognizing the risks of front-running and higher costs while preserving transparency.
Modernization is also advancing in how funds interact with regulators and investors. The IRS’s move to allow electronic filing eliminates a costly paper process. Combined with FINRA’s decision to allow e-delivery as the default, these changes reflect a shift toward digital-first solutions that reduce friction and lower costs.
At the same time, bipartisan progress on FSOC reform would introduce greater discipline into financial stability oversight, while the SEC’s proposal to modernize the definition of “small” funds reflects how much the industry has evolved. Momentum is also building behind the GROWTH Act and efforts to modernize the fund proxy system—long-standing issues that directly affect investor costs and outcomes.
The throughline is clear: ideas grounded in investor outcomes and market realities are gaining traction and delivering results. In this edition, we highlight how ICI is advancing this work—and what it means for our members and the investors they serve.
Worth a Click
ICI President and CEO Eric Pan moderates a discussion at an Investment Company Institute and Texas Stock Exchange event
- ICI President and CEO Eric J. Pan's Real Clear Markets opinion piece on private credit funds
- ICI Launches Strategic Collaboration with DCALTA on Private Assets in 401(k)s
- ICI Chief Strategic Communications Officer: "Capital Formation Is Elemental To Economic Growth”
- ICI joins 2026 DC ScopeItOut walk to end colorectal cancer
- The IRA Investor Profile: Traditional IRA Investors’ Activity, 2023
- ICI partners with the Texas Stock Exchange (TXSE)
- 2026 Investment Company Fact Book is live!
Advocating for Investment Funds
GROWTH Act Builds Bipartisan Momentum
In February, ICI sent a letter to congressional leaders urging passage of the GROWTH Act, bipartisan legislation that would defer taxation of automatically reinvested mutual fund capital gain distributions until investors actually sell their shares. Then, on Tax Day, ICI brought the issue to a wider audience with an event featuring the bill's lead House sponsors—Reps. Beth Van Duyne (R-TX) and Terri Sewell (D-AL)—alongside President and CEO Eric Pan and Chief of Government Affairs and Public Policy Tom Quaadman. The tone was optimistic: Van Duyne, a Ways and Means member, said she is hopeful the bill will be included in the next major tax legislation, and Sewell emphasized that it would help incentivize Americans build toward the middle class. Grover Norquist of Americans for Tax Reform called it such an obvious good idea that it sells itself. With 44 Republican and 33 Democratic co-sponsors in the House, the bill has strong bipartisan support as Congress considers tax legislation and must-pass funding bills.
Congresswoman Terri Sewell (D-AL) and Congresswoman Beth Van Duyne (R-TX) on a panel discussion with ICI’s Tom Quaadman
DOL Proposes Clearer Framework for Private Market Assets in 401(k) Plans
The Department of Labor proposed a rule this quarter to give retirement plan sponsors a clearer process for including private market assets in their plan lineups—an important step toward implementing President Trump's August 2025 executive order on private markets access in defined contribution plans. The proposal moves toward a more asset-neutral framework for fiduciary decision making, reinforcing that plan sponsors should evaluate investments through a prudent, well-documented process rather than categorically excluding an asset class. This approach is closely aligned with ICI's longstanding recommendations, which emphasize that regulated funds subject to the Investment Company Act can serve as an effective and well-protected vehicle for delivering private market exposure to retirement savers.
Defending Access to Private Credit Through Regulated Funds
As private credit continues to expand and more regulated funds offer investors access to the asset class, ICI has been engaging with policymakers and regulators to make the case that regulated funds—with their established governance, valuation oversight, and investor protections—are a responsible vehicle for broadening access. This quarter, ICI published a white paper on how regulated funds value private credit, addressing one of the central questions regulators and policymakers are asking as private market access grows. ICI also called on the SEC to extend principles-based co-investment relief to open-end funds, arguing that excluding them from the framework already in place for closed-end funds and BDCs leaves a significant gap for retirement savers who rely on open-end mutual funds as their primary investment vehicle.
Fund Proxy Reform Gains Traction
In an op-ed in the Financial Times, General Counsel Paul Cellupica made the case for modernizing the fund proxy voting system—a framework designed in the 1940s that now forces funds to spend enormous sums soliciting votes on matters most shareholders view as routine. ICI research found that total fund proxy campaign costs between 2020 and 2025 reached as much as $1 billion, with those costs ultimately borne by fund shareholders. The core problem is structural: the law requires a participation quorum of more than 50% of all outstanding shares, even for noncontroversial matters where approval rates routinely exceed 80%. ICI is advocating for reforms that would lower the participation threshold while requiring a higher level of approval among votes cast—preserving meaningful shareholder oversight while eliminating the worst costs of the current system.
Shaping Trump Accounts for Long-Term Success
In February, ICI submitted a detailed comment letter to the Treasury Department and the IRS with recommendations for implementing Trump Accounts, the new tax-deferred savings accounts for children born between 2025 and 2028. The letter urged Treasury to broaden its interpretation of eligible investments and provide clear guidance for employer contribution programs. ICI also recommended that Treasury clarify that a fund of funds can qualify as an eligible investment—giving families a convenient, diversified option within the program's framework. To demonstrate its confidence in the long-term success of Trump Accounts, ICI recently announced it would match the government’s contribution for employees’ children.
Global Affairs
ICI’s global engagement in the first quarter of 2026 continued to focus on promoting policy and regulatory frameworks that enable asset managers to operate effectively across markets and support competitive, well-functioning capital markets globally. Against a backdrop of heightened geopolitical tensions and rapidly changing market dynamics, our work emphasized reducing fragmentation, enabling greater retail participation in capital markets, and promoting proportionate, outcomes-based regulation that supports innovation while maintaining strong investor protections.
In Asia-Pacific, ICI engaged with policymakers on targeted reforms to improve market access, reduce operational frictions, and support proportionate regulation. Key policy work included:
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Australia: Responded to Treasury’s consultation on fund governance reforms, advocating for a more targeted, risk-based approach.
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Hong Kong: Engaged with the Securities and Futures Commission on proposed Unit Trust Code reforms, encouraging alignment with international practices.
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India: Supported proposals from the Securities and Exchange Board of India to reduce operational frictions for foreign funds investing in India.
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Singapore: Responded to the Monetary Authority of Singapore’s consultation on liquidity risk management, encouraging flexible implementation that reflects the diversity of fund structures.
In Europe, ICI focused on initiatives shaping capital markets and the regulatory frameworks that support them. Key policy work included:
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Savings and Investments Union: Published recommendations to strengthen the Pan-European Personal Pension Product as a scalable tool to support long-term retail investing.
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Market Integration and Supervision Package: Advocated for reforms that reduce national gold-plating, strengthen supervisory convergence, and preserve efficient cross-border fund operations.
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Securitization reform: Advanced ICI’s advocacy for a globally competitive EU securitization framework that supports capital formation and improves market functioning.
In the United Kingdom, ICI’s policy work focused on:
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Liquidity management tools: Responded to the FCA’s consultation on liquidity management tools, supporting flexible implementation that reflects the diversity of fund structures and investor needs.
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Transaction reporting: Contributed to the FCA’s consultation on transaction reporting reforms, emphasizing the need to reduce unnecessary burdens and support the UK’s competitiveness as a global asset management hub.
In addition to direct advocacy and consultation responses, ICI Global Affairs continued to prioritize engagement between policymakers and members, ensuring that global policy discussions are informed by practical market experience. In the first quarter, ICI hosted several high-level engagements, including an executive roundtable in Brussels with Commissioner Maria Luís Albuquerque on European competitiveness and capital markets, and a senior industry discussion in London with Andrew Bailey, Governor of the Bank of England and Chair of the Financial Stability Board, on global financial policy priorities. In Asia, ICI participated in forums in Tokyo and Singapore, bringing global perspectives to discussions on evolving regulatory approaches and market developments. ICI also continued its monthly Early Bird Exchanges in Brussels, providing an informal forum for dialogue between policymakers and industry on key legislative initiatives.
State-Level Advocacy Efforts
ICI’s state government affairs team engaged with state attorneys general, governors, treasurers, regulators, and legislative leaders through meetings, conferences, and direct outreach. These efforts helped elevate ICI’s perspective on fiduciary standards, proxy voting, unclaimed property, and capital markets issues, while strengthening relationships in key states.
- Florida: ICI worked closely with the Chief Financial Officer’s office on unclaimed property legislation (SB 1452), helping to secure improvements to the treatment of securities accounts. The legislation reflects a more modern framework that recognizes investor engagement through communications and account activity, rather than relying solely on inactivity. The bill has passed the legislature and is awaiting action by the governor.
- Maine: Building on prior engagement, ICI continued to work with the Treasurer’s Office and legislators on LD 1969, a bill that would have significantly altered Maine’s unclaimed property laws. Following a January work session, the bill advanced out of committee with amendments preserving a returned mail standard for securities accounts. ICI remains engaged as the bill awaits further consideration by the full legislature.
- New York: ICI is engaging with state policymakers on Assembly Bill A4282, emphasizing that regulated funds should not be included within the scope of the bill. ICI stated that state-level disclosure frameworks should appropriately reflect the structure and role of investment funds.
Supporting Members
Operational Support for CITs
The rapid growth of collective investment trusts (CITs) in recent years has delivered clear benefits for plans and their participants, but it has also placed new strains on operational frameworks that were not designed to support today’s scale or complexity of CIT offerings. The new white paper from ICI’s Bank Trust and Retirement Advisory Committee and Broker Dealer Advisory Committee, An Overview of Operating Collective Investment Trusts at Scale, offers a framework for implementing operational change across the CIT ecosystem. The key findings of the paper are described in a companion blog penned by John Randall, ICI’s Senior Director, Operations & Distribution. ICI’s recently launched CIT resource hub provides a single place for operational, policy, and legal information and resources for our CIT members and committees.
ICI Establishes Cybersecurity Benchmarks Across the Industry
ICI has presented the summary results of the revamped ICI Cybersecurity Benchmarking Survey for 2025. The purpose of the survey is to support ICI members in their independent assessment of cybersecurity policies and practices and to provide participating firms with useful industry benchmarks for internal management, board, and program oversight purposes. The survey was redesigned in 2025 in collaboration with member CISOs and an industry consultant to enhance clarity, relevance, and usefulness. The survey, which is open to all ICI members, is in its 10th year of providing valuable benchmarks of cybersecurity practices within the asset management industry.
Yes, Gig Workers Save for Retirement
Because gig workers can sometimes lack access to employer-sponsored plans, they are often portrayed as disengaged from long-term savings and at a heightened risk of financial insecurity in retirement. However, research from ICI found that gig workers across all age groups actually report similar rates of household retirement account ownership as non-gig workers. An ICI Viewpoints blog from Sarah Holden, ICI’s Senior Director of Retirement & Investor Research; and Michael Bogdan, Associate Economist, lays out the findings and shows how gig workers fit into the US retirement system.
America250: Invested in America
As the United States marks its 250th anniversary, ICI is highlighting a simple but important truth: regulated funds do far more than help people save. They help families build security, support business growth, and invest in communities. For millions of households, funds are one of the main ways people participate in the growth of the US economy and their communities.
- Nearly 130 million Americans own mutual funds, ETFs, or other registered funds, and for many, the journey starts at work.
- The same regulated funds that help families save for retirement, education, and other long-term goals also channel household savings into productive investment across the economy.
- Ordinary investors, through their funds, are helping finance schools, hospitals, transportation networks, water systems, and other essential public works in communities across the country.
Explore how ICI is celebrating America250 by showing how our industry is Invested in America.
In the News
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“We're not going out saying to Americans around the country, ‘Hey, get into [private investments] now,” says ICI Chief Executive Officer Eric Pan. “What we’re saying is that we believe there's a legitimate case for retail access to private markets and we want to make sure the policy environment makes it possible for this to happen.” Read the article |
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The Investment Company Institute, an asset management trade group, has asked the government to make [Trump] accounts portable and to let financial companies create a “robust and competitive marketplace” for account trustees and custodians. The government has said it intends to eventually expand the program to make the accounts transferable. |
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The Investment Company Institute, a trade organization representing the asset-management industry, has pushed for an open marketplace and, failing that, for the initial accounts to not be branded with the name of the firm the Treasury Department chooses. Read the article |
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Eric Pan walks through money market flows, noting that a great deal of money still remains on the sidelines. He says this shows a “lot of potential” in the marketplace and talks through why retail investors are staying cautious right now. “A lot of Americans are doing exactly what they should do right now,” he says, as they rebalance portfolios and diversify. |