Eric Pan, the CEO of the Investment Company Institute, has created a “toxic” work environment and stoked a “crisis of confidence” within the organization, according to anonymous letters sent to the organization’s board of directors and NOTUS interviews with five sources with direct knowledge of the workplace.
The sources say these accusations, which the Investment Company Institute denies, have roiled the Washington lobbying powerhouse that represents the interests of the asset management industry and whose member companies include financial giants such as Fidelity, Vanguard, Morgan Stanley and BlackRock. Investment Company Institute members collectively manage more than $37.7 trillion in assets.
“The environment at ICI has become toxic due to Eric’s personal behavior and overall management. Staff across ICI report that he is arrogant, condescending, prone to lashing out, and routinely conducts combative interrogations of employees at all levels of the organizations,” one of the previously unreported letters, dated February 2026, reads.
The letter goes on to say that “[Pan’s] behavior is irreparably harming the reputation and effectiveness of ICI at a time of historic opportunity in Washington for the industry” and urges the board “to review Eric’s leadership, including interviews with Washington ICI constituents at member companies and law firms.”
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Erica Richardson, Pan’s chief of staff and chief strategic communications officer at the Investment Company Institute, denied the allegations.
“Attacks from anonymous sources on ICI management and our company culture are patently false and not supported by facts or any on the record sources. There is no basis for these spurious claims,” Richardson told NOTUS.
In a separate letter dated April 2026, the authors say that they “continue to write anonymously to protect those who have given us information.”
The February letter also accuses Pan of unspecified “inappropriate” behavior toward the organization’s former top female lobbyist, Kristin Solheim. A few months after Solheim’s then-boss, John Emling, raised concerns about Pan’s behavior to human resources, the Investment Company Institute fired him during the first quarter of 2025. He is now the head of government affairs at Motorola.
The Investment Company Institute fired Solheim in October 2025. Her firing shocked sources who described Solheim as a kind, well-liked and experienced lobbyist. Previously an in-house lobbyist at Citigroup for almost a decade and at Visa for five years, Solheim joined the Investment Company Institute as a government affairs specialist in March 2023. She was listed as senior government affairs officer in the trade association’s annual report to members published the same month she was fired.
“[I]t is widely known that whistle blower statements regarding Eric’s inappropriate behavior towards the same very well connected female lobbyist were involved in the firing of her boss last year,” according to the letter to the Investment Company Institute’s board. “Her firing is perceived to be an act of retribution.”
An independent legal investigation commissioned by the Investment Company Institute found the organization’s decision to terminate Solheim was legally justified and based on performance failures documented by Tom Quaadman, chief of government affairs and public policy at the Investment Company Institute, according to excerpts from the review described to NOTUS by Richardson, who confirmed the investigation came after the board received the February letter. The review also found the whistleblower allegations, which were not the subject of the investigation, were not a factor in Quaadman’s decision to fire Solheim.
Her Republican counterpart, Wyatt Stewart, quit sometime between Emling and Solheim’s departures.
Neither Solheim nor Stewart responded to requests for comment. Emling declined to comment.
The April letter to the board says that “a member of the ICI staff told us morale remains low.” It also alleges that Pan was the subject of a 2023 investigation.
Richardson confirmed there was an investigation in 2023 but said the review found the allegations by a departing employee of gender discrimination were baseless.
NOTUS could not identify who sent the letters to the Investment Company Institute’s board.
But NOTUS spoke with five sources with direct knowledge of events inside the Investment Company Institute about the February letter’s characterization of Pan, and they each expressed their own concerns about his leadership. The sources were not authorized to speak publicly about the Investment Company Institute’s internal affairs, and they spoke to NOTUS on the condition of anonymity to avoid potential retaliation.
“I don’t think it’s hyperbole to say he’s running it into the ground,” one source told NOTUS. The source described Pan as an “arrogant” leader who “treats people very badly.”
Andrew Schlossberg, president and CEO of the independent investment management company Invesco and chair of the Investment Company Institute board, did not respond to questions about what actions, if any, the board had taken.
When asked by NOTUS if Pan’s job was at risk or whether he had been formally or informally reprimanded or was under any kind of internal investigation, Richardson replied, “The claims are false so, no.”
Marc Edelman, a partner at the law firm Morgan & Morgan, told NOTUS that there is “no law requiring an employer to investigate every single anonymous allegation that’s made.”
“However, when you’re put on notice of potential harassment or discrimination or retaliation, the law does require the employer to take prompt and remedial action to ensure that the offending behavior doesn’t recur. And common sense would dictate that starts with an investigation,” Edelman said.
“If the board was on notice of inappropriate and potentially unlawful behavior and buried its head in the sand rather than take some type of appropriate steps to at least try to verify the validity of the allegations, I’d really like that case,” Edelman added.
NOTUS requested an interview with Pan, but Stephen Bradford, the Investment Company Institute’s managing director for strategic communications, told NOTUS that Pan was traveling. The organization did not make Pan available to talk.
Pan, who earned undergraduate and law degrees from Harvard University, previously served as the head of international regulatory policy at the Securities and Exchange Commission and the director of the office of international affairs at the Commodity Futures Trading Commission. He became president and CEO of the Investment Company Institute in November 2020.
His total compensation topped $3.2 million between October 2023 and September 2024, according to the Investment Company Institute’s latest annual nonprofit tax report to the IRS.
Pan’s arrival marked a shake-up for the Investment Company Institute. Around three-quarters of the communications team quit or was fired about a year into his tenure, according to The Financial Times-owned publication Ignites, which covers the asset management industry.
Two sources told NOTUS that the board of directors requested that Pan take management classes early in his tenure.
Richardson told NOTUS that the board gave Pan an executive coach as part of his transition to CEO, and that all senior executives at the Investment Company Institute have access to executive coaching.
Meanwhile, dozens of Investment Company Institute employees have quit or been fired since Pan took over the organization, according to NOTUS’ review of LinkedIn histories and discussions with sources. Since June 2024, six of the 11 executives listed on the trade association’s most recent IRS tax return have left the Investment Company Institute.
“As a staff, we are continually evaluating our strategies and approaches to engaging with policymakers. At times, this necessitates adding new capabilities or sunsetting functions and roles that no longer advance our advocacy goals. This is expected of any organization that exists in a dynamic environment, including trade associations in Washington, DC,” Richardson said in a statement to NOTUS when asked about the turnover.
The Pan-era practice of escorting fired employees out of the building without letting them speak to their colleagues has also “shattered company norms,” according to the February letter, which added that Solheim was marched out of the building that way after she was fired last fall.
When asked about fired employees being escorted from the building, Richardson told NOTUS that the Investment Company Institute follows best security practices, including removing terminated employees’ key card and network access.
The Investment Company Institute has a large presence in Washington.
Last year, the Investment Company Institute spent $4.9 million lobbying the federal government on a range of issues, including the Republican tax bill, which included several wins for the asset management industry. Pan regularly promotes his organization’s priorities in person and on social media, such as when he earlier this year praised the U.S. House’s passage of a financial regulation bill as a “win for investors.”
The Investment Company Institute also shook up its federal lobbying operation in 2025. The trade association fired two firms they had worked with for years, Public Strategies Washington and CGCN, an all-Republican firm with close ties to the White House and conservatives on Capitol Hill.
“After 23 years working with the Investment Company Institute, CGCN was surprised by the decision to move in a different direction. Our model is to engage directly and operate across the aisle — an approach we’ll continue for clients who value it,” Sam Geduldig, CGCN’s managing partner, told NOTUS.
The Investment Company Institute fired CGCN after Geduldig made a “joke” at a Republican fundraiser, according to the Substack publication Capitol Account. The publication reported that Geduldig had suggested to Rep. Andy Barr that Republicans take a cue from Democrats to “weaponize” the federal government and go after executives, such as BlackRock CEO Larry Fink, who advocate for the “environment, social, and governance”, or ESG, policies, which conservatives, including Barr, love to hate.
The April letter to the board of directors makes a variety of other assertions involving Pan, including that “a senior House Republican” refuses to meet with him.
NOTUS was unable to identify this lawmaker, although two Republican Senate chiefs of staff, who were not authorized to speak publicly, told NOTUS they would not meet with the Investment Company Institute. One of the chiefs told NOTUS that the Investment Company Institute firing CGCN over a climate-change joke was “toxic with Republicans on the Hill.” The other told NOTUS they would not meet with the Investment Company Institute “after they treated Sam like shit.”
One House Republican aide, however, told NOTUS that “ICI continues to be a great partner with Congress in the pursuit of policies that benefit American investors and retirees.” And another senior Republican Senate aide told NOTUS that their office had a “great partnership” with the Investment Company Institute and that “overall the ICI brand is very strong.”
Many Investment Company Institute members are regulated by the SEC. Pan and two other Investment Company Institute executives met with SEC Chair Paul Atkins in July, according to the chairman’s public calendar.
The Investment Company Institute hired four new lobbying firms between July 2025 and March 2026, according to registrations filed under the Lobbying Disclosure Act.
The new hired guns include Magill Associates’ John Magill, who was previously chief of staff to former Republican Rep. Wally Herger; Morgan, Lewis & Bockius’ Richard LaFalce, a former IRS assistant branch chief; Longbow Public Policy Group’s Andrew Siff, who previously worked for Republican Sen. Mitch McConnell and former Labor Secretary Elaine Chao; and several lobbyists at Federal Hall Policy Advisors, including Douglas Nappi, a former general counsel on the Senate Banking Committee.
“ICI has transitioned many of its public-facing lobbying and advocacy capabilities in the last year, beginning with hiring Tom Quaadman as the chief government affairs and public policy officer,” Richardson said in a statement to NOTUS. “Tom has been effective in representing ICI before the new Administration, overseen a series of bipartisan successes in our congressional advocacy, and made sure ICI members are more engaged with our government affairs work.”
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