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Comments on the Investor Advocate Report Regarding Investor Testing of Proposed Form CRS
The IAA raised concerns about the investor testing but noted that it confirms the IAA’s previous comments that Form CRS be simplified and streamlined, and that the SEC use an integrated approach by combining Form CRS with the Form ADV brochure.
December 04, 2018
Comments on Regulation Best Interest, Form CRS, and Advisers Act Fiduciary Duty Interpretation
The IAA supported the SEC’s efforts to extend fiduciary principles to all financial professionals. Regarding proposed Regulation Best Interest, the IAA raised concerns about the narrow scope and application of the rule. The IAA recommended investor testing and streamlining of proposed Form CRS and discussed the need for a more principles-based approach and certain clarifications in the fiduciary duty interpretation.
August 06, 2018
Remarks at SEC Investor Advisory Committee Meeting on Regulation Best Interest and Form CRS
Karen Barr, president & CEO of the IAA, commended the SEC for taking action to strengthen the standard of conduct for broker-dealers. She discussed the IAA’s concerns about the scope of proposed Regulation Best Interest. Regarding proposed Form CRS, the IAA has significant concerns about the potential for investor confusion and supports investor testing.
June 14, 2018
The IAA requested that the SEC make public the results of investor testing in connection with the standards of conduct proposals, and an extension of the comment period to incorporate results of the investor testing.
May 25, 2018
This article discusses certain U.S. reporting and compliance obligations for advisers and private funds.
March 21, 2023
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June 08, 2022
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