In a comment letter on the Securities and Exchange Commission's universal proxy rule proposal, the Investment Company Institute supported the exclusion of investment companies as issuers from the scope of the rule. ICI General Counsel Dorothy Donohue said funds are subject to both Investment Company Act and state law provisions that provide specific rights to shareholders to approve fundamental features of a fund. She also noted that a typical fund's governance structure differs from that of operating companies and would be disrupted by split-ticket voting. "With no opportunity to profit from a ‘discount’ between the market price of a mutual fund’s shares and its NAV, dissidents have little incentive to nominate directors or otherwise take steps to influence the management of mutual funds," she wrote. Read the original story from Bloomberg BNA.