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The IAA urged the SEC to exclude SEC-registered investment advisers and their clients, including private funds, from the proposed definition of dealer.
The SEC has unleashed a flurry of rule proposals that, if enacted as proposed, will significantly alter the regulatory, disclosure and reporting obligations for managers who cater to the private fund market.
The IAA opposes the proposed private fund adviser prohibited activities and the preferential treatment rules. We offer reasonable alternatives to increase transparency and address investor protection concerns that do not depart from the principles-based approach to the Advisers Act. We also oppose retroactive application of the rules
The IAA recommends that the SEC reconsider its proposal to require current reporting of events on Form PF, amend proposed triggering events, and refrain from defining “digital assets.”
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