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Comments on Fiduciary Provision in Maryland Senate Bill 786
The IAA requested that the Maryland Senate Finance Committee remove references to federal covered advisers from a fiduciary provision in a bill and clarify that the provision would not apply to investment adviser representatives of federal covered advisers. These changes would preserve the division of regulatory oversight of investment advisers between the SEC and the states.
March 08, 2019
Comments on Fiduciary Provision in Maryland House Bill 1127
The IAA requested that the Maryland House Economic Matters Committee remove references to federal covered advisers from a fiduciary provision in a bill and clarify that the provision would not apply to investment adviser representatives of federal covered advisers. These changes would preserve the division of regulatory oversight of investment advisers between the SEC and the states.
March 08, 2019
Comments on the Nevada Securities Division’s Draft Regulations Regarding Fiduciary Duty
The IAA urged the Nevada Securities Division to make clear that its draft regulations regarding fiduciary duty do not apply to SEC-registered investment advisers or their representatives, because states are preempted from imposing substantive regulation on SEC-registered advisers.
March 01, 2019
Comments on the Washington Administrative Code (WAC) Amendments to Investment Adviser Rules
The IAA raised concerns that several of the State of Washington’s proposed rules for investment advisers were written to apply to SEC-registered advisers, which raises preemption issues.
January 08, 2019
Comments on New Jersey Notice of Pre-Proposal Regarding Fiduciary Duty
The IAA requested that the New Jersey Bureau of Securities make clear that it does not intend to apply a proposed fiduciary duty rule to SEC-registered investment advisers because SEC-registered advisers are already subject to a fiduciary duty and states are preempted from extending substantive regulation to SEC-registered advisers.
December 13, 2018
Comments on NASAA’s Proposed Revision to Statement of Policy Regarding Real Estate Investment Trusts
IAA comments on NASAA proposal on non-traded REITS; objects to applying the proposal and the concentration limit to federal covered advisers.
September 13, 2022
Comments on Nevada’s Revised Proposed Fiduciary Duty Regulations
The IAA submitted a letter to Nevada expressing appreciation that its revised proposed regulations regarding fiduciary duty includes language clearly stating that the provisions of the regulation would only apply to an SEC Adviser as permitted by the National Securities Markets Improvement Act of 1996 (NSMIA).
August 02, 2022
Comments on Oklahoma’s Amendments to Standards of Ethical Practice Under the Oklahoma Securities Act
The IAA recommended clarifying that the rule would not apply to investment adviser representatives of SEC-registered investment advisers and recommended removing certain redundant language.
March 23, 2020
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