Comment on OMB-2026-0034-0001
Metis Group IncOpposeBusiness
Summary: Ivana Karina Harrington, President of Metis Group Inc., opposes the requirement for prior written approval for fundraising and investment-management costs. She argues that this adds unnecessary administrative burdens and delays routine activities, suggesting instead that the agency use documentation standards or a deemed-approval timeline.
§200.442 Fundraising and investment management costs and prior-approval burden
Requiring prior written approval for fundraising and investment-management costs adds a transactional approval step without a stated response timeline.
Routine, allowable institutional activities are delayed pending agency response, and agencies absorb added approval volume.
I recommend to replace prior approval with documentation-and-allocability standards, or impose a maximum agency response time with deemed-approval after lapse.
Ivana Karina Harrington, President Metis Group Inc.