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The IAA participated in a meeting of the SEC’s AMAC to discuss business and regulatory challenges facing smaller advisers, including outsourcing, scalability, cyber, CUSIP fees, cumulative impact of regulation, and more. We presented data from the IAA’s 2021 Adviser Industry Snapshot to underscore that the “typical” adviser is a small business by any measure and called on the SEC to take smaller advisers into account when setting policy and exam expectations.
The IAA urged the SEC to update the definition of “small business” under the Investment Advisers Act and better tailor its regulations for smaller advisers. The Pay-to-Play Rule was included in the list of rules to be reviewed under the Regulatory Flexibility Act, and the IAA discussed the rule’s unnecessary complexity and significant strict liability penalties.
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.
The IAA strongly supported the Investment Adviser Regulatory Flexibility Improvement Act legislation because it would require the SEC to develop an alternative method under which investment advisers are classified as small entities under the Regulatory Flexibility Act.
The IAA recommended that the Senate Banking Committee could spur economic growth by ensuring that the SEC give appropriate consideration in its rulemakings to the regulatory burdens faced by smaller advisers.
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