IAA Submits Additional Comments on SEC’s Safeguarding Proposal
The IAA submitted a comment letter urging the SEC to make additional changes to its proposed rule relating to the safeguarding of advisory client assets.
October 30, 2023
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IAA Supports SEC Proposal on Protection of Client Information with Recommended Changes
The IAA supports the SEC’s proposal to amend the rules governing the protection of clients’ non-public personal information (PII), subject to certain recommendations that we believe would further the SEC’s objectives while more effectively protecting investors and streamlining unnecessary operational and compliance burdens on advisers.
June 05, 2023
IAA Letter to SEC on Safeguarding Advisory Client Assets Proposal
IAA comment letter urging the SEC to make substantial changes to its proposed rule relating to the Safeguarding of Advisory Client Assets.
May 08, 2023
Comments on Proposed Cybersecurity Rules for Advisers
We recommend changes to proposed cybersecurity rules that would require investment advisers to adopt and implement written cybersecurity policies and procedures with specified elements, report significant adviser cybersecurity incidents to the Commission, disclose significant adviser cybersecurity risks and incidents to clients, and maintain related books and records.
April 11, 2022
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
Application of Rule 15c2-11 to the Fixed Income Markets
The IAA, together with other associations, called on the SEC to revisit an ill-fitting application to the fixed income markets of a new rule that was intended to cover over-the-counter retail equity securities markets.
September 23, 2021
Non-DVP Settlement and the Custody Rule
Responding to an SEC letter to the IAA seeking feedback, we submitted a joint letter to SEC staff explaining why transactions that settle non DVP should not be subject to the Custody Rule.
May 13, 2021
Comments on Investment Company Act Cross-Trading Rule 17a-7
The IAA called on the SEC to modernize the Investment Company Act cross-trading rule, recommending that the SEC reverse a new definition of “readily available market quotations,” amend the rule to codify relief related to board oversight, and recognize the protections afforded to fund shareholders by the Advisers Act fiduciary duty.
April 11, 2021