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The IAA submitted a comment letter to the SEC requesting that the agency withdraw its proposed rules regarding potential conflicts of interest associated with the use of predictive data analytics and other technologies by advisers in investor interactions.
October 10, 2023
The IAA joined other trade groups in requesting that the SEC extend the comment period for its proposed rules addressing conflicts of interest associated with the use of predictive data analytics by advisers and broker-dealers in investor interactions.
August 15, 2023
Comments on the Massachusetts Securities Division’s Proposal on Fiduciary Conduct Standard
The IAA argued that the proposed fiduciary conduct standard should not apply to SEC-registered investment advisers or their representatives because that would be contrary to preemption provisions and the National Securities Markets Improvement Act of 1996.
July 25, 2019
Comments on Fiduciary Provision in Maryland Senate Bill 786
The IAA requested that the Maryland Senate Finance Committee remove references to federal covered advisers from a fiduciary provision in a bill and clarify that the provision would not apply to investment adviser representatives of federal covered advisers. These changes would preserve the division of regulatory oversight of investment advisers between the SEC and the states.
March 08, 2019
Comments on Fiduciary Provision in Maryland House Bill 1127
The IAA requested that the Maryland House Economic Matters Committee remove references to federal covered advisers from a fiduciary provision in a bill and clarify that the provision would not apply to investment adviser representatives of federal covered advisers. These changes would preserve the division of regulatory oversight of investment advisers between the SEC and the states.
March 08, 2019
Comments on the Nevada Securities Division’s Draft Regulations Regarding Fiduciary Duty
The IAA urged the Nevada Securities Division to make clear that its draft regulations regarding fiduciary duty do not apply to SEC-registered investment advisers or their representatives, because states are preempted from imposing substantive regulation on SEC-registered advisers.
March 01, 2019
Comments on the Washington Administrative Code (WAC) Amendments to Investment Adviser Rules
The IAA raised concerns that several of the State of Washington’s proposed rules for investment advisers were written to apply to SEC-registered advisers, which raises preemption issues.
January 08, 2019
Comments on New Jersey Notice of Pre-Proposal Regarding Fiduciary Duty
The IAA requested that the New Jersey Bureau of Securities make clear that it does not intend to apply a proposed fiduciary duty rule to SEC-registered investment advisers because SEC-registered advisers are already subject to a fiduciary duty and states are preempted from extending substantive regulation to SEC-registered advisers.
December 13, 2018
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