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.
IAA Petitions SEC to More Accurately Consider Impact of Regulations on Smaller Advisers
As part of the IAA’s ongoing advocacy on behalf of smaller advisers, we submitted a rulemaking petition to the SEC to require the agency to adhere to its statutory obligations to accurately analyze the impact of its regulations on smaller advisers and consider less onerous alternatives.
September 14, 2023
IAA Supplemental Letter to SEC on Cybersecurity Survey Results
Results of the IAA’s 10-question member survey on the costs and burdens associated with the SEC’s cybersecurity proposal, which we believe the SEC severely underestimates. These results can help members benchmark their cybersecurity-related costs.
December 19, 2022
IAA Letter to FINRA on Complex Products and Options
The IAA objected to FINRA’s questions on whether standards for complex products and options should apply to investment advisers because FINRA has no authority over investment advisers.
May 09, 2022
Comments on Proposed Cybersecurity Rules for Advisers
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.
April 11, 2022
IAA Comment Letter on Beneficial Ownership (Schedules 13D and 13G)
We recommend changes to proposed accelerated Schedules 13D and 13G filing deadlines, cash-settled derivative securities, and definition of a group.
April 11, 2022
IAA and Trade Associations Urge SEC to Lengthen Short Comment Periods
The IAA and other trade associations urge the SEC to provide more time to comment on the many concurrent consequential rule proposals to allow for more thorough and meaningful feedback.
April 05, 2022
The IAA commented on the SEC’s re-proposal of amendments to Form 13F that (i) additional identifying information in Form 13F is not needed, (ii) the SEC could provide managers with flexibility to choose an alternative identifier to a CUSIP and should study holistically issues raised by requiring the use of licensed security identifiers, and (iii) the SEC should not make technical amendments to the well-established rounding conventions or how a security’s value is reported.
December 17, 2021
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