Based on member feedback, we are in the process of redesigning our Resource Library, as well as working on an improved search feature. In the meantime, if you need assistance finding a resource or would like to discuss an issue with a member of the legal team, please contact us at IAALegalTeam@investmentadviser.org.
For the third year in a row, implementing the SEC’s Marketing Rule for Investment Advisers remains the number one focus for investment adviser chief compliance officers, according to the 2023 Investment Management Compliance Testing Survey.
We recommend changes to proposed cybersecurity rules that would require investment advisers to adopt and implement written cybersecurity policies and procedures with specified elements, report significant adviser cybersecurity incidents to the Commission, disclose significant adviser cybersecurity risks and incidents to clients, and maintain related books and records.
The IAA supported the SEC’s efforts to make the Advertising Rule less prescriptive, but expressed concern over the expansive definition of “advertisement” and onerous pre-approval requirements in the Advertisements Proposal. The IAA also raised concerns about the proposed expansion of the Solicitation Rule to private fund investors and recommended limiting the rule to specific types of non-cash compensation.
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