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The IAA supports the proposal to reinstate the CPO registration exemption for SEC-registered advisers and replace the interim relief that the CFTC had provided in a staff no-action letter. The proposed changes will reduce burdens and duplicative regulation where an adviser operates a qualifying commodity pool for sophisticated investors. We also recommend changes to the provisions around redemptions and qualified eligible person investors.
The IAA filed a comment letter strongly supporting the SEC’s proposed Regulation E-Delivery and recommending refinements to make the framework more evergreen, flexible, and operationally workable.
The IAA joined a letter opposing changes to California’s unclaimed property law that would allow the state to take custody of and liquidate assets after three years of inactivity by the investor.
The IAA requests that Missouri remove the Chartered Investment Counselor (CIC) designation from a proposed amendment to a regulation regarding waivers from examinations. The CIC designation was discontinued in 2025.
AI has emerged as the overwhelming top compliance priority for investment adviser firms, according to the 2026 Investment Management Compliance Testing Survey.
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