The IAA files comments on NASAA proposal on non-traded REITs and objects to applying the concentration limit to federal covered advisers; re-proposal follows NASAA’s 2022 proposal that was not adopted.
May 28, 2025
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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 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
Comments on the Massachusetts Securities Division’s Fiduciary Duty Rule
The IAA supported the Massachusetts Securities Division’s efforts to clarify that its proposed Fiduciary Conduct Standard does not apply to federal covered advisers and applies to the representatives of SEC-registered advisers only as permitted by NSMIA.
January 06, 2020
Comments on the Massachusetts Securities Division’s Proposal on Fiduciary Conduct Standard
The IAA argued that the proposed fiduciary conduct standard should not apply to SEC-registered investment advisers or their representatives because that would be contrary to preemption provisions and the National Securities Markets Improvement Act of 1996.
July 25, 2019
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