IAA Letter to SEC on Safeguarding Advisory Client Assets Proposal
IAA comment letter urging the SEC to make substantial changes to its proposed rule relating to the Safeguarding of Advisory Client Assets.
May 08, 2023
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The IAA urged the SEC to update the definition of “small business” under the Advisers Act and better tailor its regulations for smaller advisers. The Custody Rule was included in the list of rules to be reviewed under the Regulatory Flexibility Act, and the IAA described the rule as overly complex, unduly burdensome, and causing unnecessary confusion.
December 27, 2018
IAA, Joint Letter on the February 2017 SEC Guidance on Inadvertent Custody
The IAA and another trade association discussed concerns related to SEC staff guidance from February 2017 on the Advisers Act Custody Rule and inadvertent custody.
March 07, 2018
SEC No-Action Letter to IAA on Custody and Standing Letters of Authorization (SLOAs)
The SEC issued a no-action letter to the IAA regarding the Advisers Act custody rule and SLOAs. The SEC staff stated that advisers would have custody under these circumstances but provided no-action relief from the surprise examination requirement if certain conditions are satisfied.
February 21, 2017
The IAA joined 11 other trade associations to submit a letter to the SEC requesting an extension of the comment period for the Safeguarding Client Assets Proposal.
March 03, 2023
Non-DVP Settlement and the Custody Rule
Responding to an SEC letter to the IAA seeking feedback, we submitted a joint letter to SEC staff explaining why transactions that settle non DVP should not be subject to the Custody Rule.
May 13, 2021