Compliance Control: Books and Recordkeeping Requirements
Outline of Advisers Act Rule 204-2 requiring advisers to maintain a comprehensive set of records supporting their investment adviser activities.
June 12, 2023
Based on member feedback, we are in the process of redesigning our Resource Library, as well as working on an improved search feature. In the meantime, if you need assistance finding a resource or would like to discuss an issue with a member of the legal team, please contact us at IAALegalTeam@investmentadviser.org.
Your Search Results
Supplemental Comments on SEC Proposal to Shorten Securities Settlement Cycle to T+1
The IAA has submitted supplemental comments on the SEC’s proposal to shorten the securities settlement cycle to T+1. Our supplemental letter requests that the SEC push back the T+1 settlement cycle compliance date to September 3, 2024, replace the proposed requirement of a written agreement with a requirement that investment advisers adopt policies and procedures, and that the SEC take further action to reduce disruption in the foreign exchange (FX) markets.
October 19, 2022
October 2022 Sample Examination Letter – Recordkeeping and Personal Devices
This is a sample SEC examination letter from October 2022 regarding recordkeeping and the use of personal devices.
October 19, 2022
IAA has joined several trade organizations to request a later compliance date for T+1 securities settlement. The SEC has proposed a March 2024 compliance date – the letter requests a September 2024 compliance date to allow the industry adequate time for the transition.
October 10, 2022
SEC Brings New Off-Channel Communications Cases, More to Come
SEC and CFTC enforcement cases for recordkeeping and supervision failures involving off-channel electronic communications on personal devices.
August 10, 2023
Comments on SEC Proposal to Shorten Securities Settlement Cycle to T+1
We support the SEC’s proposal to shorten the securities settlement cycle to T+1 and provide recommendations that we believe will better balance the SEC’s desire for information with operational realities of how investment advisers engage in securities trading. We also strongly encourage the SEC to not consider moving to a T+0 settlement cycle until the T+1 settlement cycle has been implemented for at least two years and the SEC has had adequate time to analyze data from all stakeholders.
April 11, 2022
Electronic Communications Conundrum: Risks vs. Regulatory Obligations
16 steps to take in light of the SEC's enforcement case for supervisory and recordkeeping failures stemming from the use of personal devices for business communications.
February 18, 2022