Comments on Interim final rule: Investment Company Liquidity Risk Management Programs; Commission Guidance for In-Kind ETFs

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from the Office of Commissioner Kara M. Stein regarding a February 27, 2018, meeting with representatives of the Investment Company Institute (ICI)
Public Comment Michael R. Granito, Chief Risk Officer, Federated Investors, Inc.
Public Comment Dechert LLP
Public Comment John L. MacCarthy, Executive Vice President, Chief Legal Officer, Nuveen, LLC
Public Comment Michelle Beck, Executive Vice President, Chief Risk Officer, Nuveen, LLC
Public Comment Cynthia M. Clarke, General Counsel, Wellington Management Company LLP
Public Comment Christopher Edge, VP/Head of Investment Risk Management, T. Rowe Price Associates, Inc.
Public Comment Phil Fontana, Head of Product Development & Investment Risk Over, Hancock Investments
Public Comment John M. Zerr, Managing Director, General Counsel, Wealth Managem, Invesco Management Group, Inc.
Public Comment Rodney Comegys, Principal, Global Head of IMG Risk, Vanguard Funds
Public Comment Paul Schott Stevens, President and CEO, Investment Company Institute
Public Comment Meredith Jackson, General Counsel, The TCW Group, Inc.
Public Comment Timothy W. Cameron, Asset Management Group - Head, Securities Industry and Financial Markets Association
Public Comment Paul Schott Stevens, President and CEO, Investment Company Institute

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-03-18
Release Number
IC-33010
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