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Summary Report: 2023 Investment Management Compliance Testing Survey
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.
July 13, 2023
Comments on SEC Staff Roundtable on Proxy Process
The IAA discussed investment advisers’ use of proxy advisory firms for a range of services and that increased regulation of these firms would increase costs for advisers and their clients. The IAA also discussed advisers’ understanding of their obligations to vote proxies in the best interest of their clients.
December 31, 2018
The IAA recommended that the Committee focus on weaknesses in the infrastructure of the proxy system, and strongly objected to efforts to restrict advisers’ use of proxy advisory firms and to regulation that would make those services more expensive and increase barriers to entry.
December 06, 2018
Comments on SEC Proxy Voting Advice Proposal
We support the SEC’s proposal regarding proxy voting advice provided by proxy advisory firms and request that the SEC rescind both the 2019 and 2020 guidance for investment advisers on proxy voting.
December 27, 2021
Comments on SEC’s Form N-PX/Say-on-Pay Proposal
The IAA recommended the SEC revise the proposed requirement to report shares loaned but not recalled for a say-on-pay proxy vote by a reporting person and instead require a narrative disclosure.
December 14, 2021
Comments on DOL ESG and Proxy Proposal
We support the DOL’s proposal related to ESG investing and proxy voting and recommend that the DOL remove certain ESG-specific language in the rule text and remove the proposed “collateral benefit” disclosure.
December 13, 2021
Comments on DOL Proxy Proposal
The IAA strongly opposed and urged the DOL to withdraw its proposal on proxy voting and the selection and monitoring of proxy advisory firms because it represents a significant departure on how plan fiduciaries view their proxy voting responsibilities, and would substantially increase compliance costs without providing measurable benefits to plan participants and beneficiaries.
October 05, 2020
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