规模经营集体投资信托概述

March 2026 Table of Contents 2Acknowledgements3Executive Summary5Understanding the CIT Landscape6Operational Inefficiencies in CITs6Learning from the Mutual Fund Industry7CIT Operating Structures7Risks and Inefficiencies in Manual Account Onboarding at CITs8Applying the NSCC Mutual Fund Profile Service to Product Attribute Management8Data Automation: MFPS II9New Account Setup: Activities Necessary for the Establishment of an Account in Level 3 (L3) or Omnibus10Trading and Settlement Automation11From Manual Pricing to Automated Dissemination11Reconciliation Enhancements12Enhancing Plan-Level Transparency Through Omni/SERV12Regulatory and Fiduciary Considerations for CITs13Mitigating Risks Through Automation13The Path Forward for CITs: Building Industry Consensus14Conclusion14References and Resources Acknowledgements ICI acknowledges and gives special thanks to American Funds, Charles Schwab & Co., DTCC, Reliance Trust(an FIS Company), T. Rowe Price Associates, Inc., and Vanguard for their time, insights, and contributions tothis paper. About ICI The Investment Company Institute (ICI) is the leading association representing regulated investment funds.ICI’s mission is to strengthen the foundation of the asset management industry for the ultimate benefit of thelong-term individual investor. Its members include mutual funds, exchange-traded funds (ETFs), closed-endfunds, and unit investment trusts (UITs) in the United States, and UCITS and similar funds offered to investorsin other jurisdictions. ICI also represents its members in their capacity as investment advisers to collectiveinvestment trusts (CITs) and retail separately managed accounts (SMAs). ICI has offices in Washington DC,Brussels, and London. Copyright ©2026 by the Investment Company Institute. All rights reserved. Executive Summary Collective investment trusts (CITs) have seen rapid growth in recent years, driven by increasing demand fromretirement plan sponsors, advisors, and institutional investors seeking cost-efficient, flexible investmentstructures. The demand to expand CIT access in retirement plans has reached the Congressional level, withlegislation to allow CITs in 403(b) retirement plans currently pending in Congress.1 If passed, this legislationwould add to the demand for these products—and increase the need for CITs to operate at scale. However, the operational infrastructure supporting the processing of plan-level transactions for participantswithin CITs has not kept pace with CIT adoption. In many cases, operational processes remain rooted in manual,fragmented workflows that rely heavily on email exchanges, spreadsheets, manual wires, and phone calls. Thesemethods are inefficient and expose firms to operational, compliance, financial, and reputational risks. The mutual fund industry faced similar challenges with processing shareholder transactions decades agoand addressed them through automation, standardization, and enhancements to National Securities ClearingCorporation (NSCC) services, such as the Mutual Fund Profile Service, Fund/SERV, Networking, and Omni/SERV.2With enhancements to these services, the same infrastructure that has delivered accuracy, efficiency, andscalability for mutual funds can now be fully leveraged to deliver that same ability for CITs to operate at scale.This paper outlines the risks inherent in current practices and demonstrates how applying NSCC’s establishedsolutions can transform the operational landscape for CITs. This paper suggests that the CIT industry could extend similar mutual fund systems and processes to CITs.Leveraging NSCC services for product data, trading, settlement, and transparency provides a clear framework to: »Reduce costs and errors through automation»Improve regulatory compliance with the Internal Revenue Service (IRS), Department of Labor (DOL), andOffice of the Comptroller of the Currency (OCC), as well as state-based regulators when applicable»Enhance fiduciary oversight for trustees»Support scalability as CIT adoption accelerates Total CIT Assets and Growth Rate Billions of dollars, year-end Note:2024CITsizingreflectstotaltrusteedassets.Prioryearassetshavebeenrestated.TheOfficeoftheComptrolleroftheCurrency,whichregulatescollectiveinvestmentfunds,definesthemintheCodeofFederalRegulations(12CFR§9.18)asincludingtwotypesoffundstructures—bankcommontrusts,frequentlycalledA1fundsinreferencetotheparagraphoftheCodeinwhichtheyaredefined,andcollectivetrustfunds,similarlycalledA2funds.DatashowntracksprimarilyA2CTFs(availabletoretirementplans).Along-termcapitalmarketappreciationassumptionof6.4%wasusedtoprojectCITassets. Source:The Cerulli Report—U.S. Defined Contribution Distribution 2025,available athttps://www.cerulli.com/reports/us-defined-contribution-distribution-2025. Total Corporate Defined Contribution Assets and Growth Rate Billions of dollars, year-end Understanding the CIT Landscape More retirement plan sponsors have incorporated CITs as options in 401(k) plan l