IAA Submits Supplemental Letter on Dealer Proposal
The IAA has submitted a supplemental comment letter urging the SEC to exclude SEC-registered investment advisers and their clients from the proposed definition of dealer.
October 17, 2023
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T+1 Securities Settlement Industry Implementation Playbook, by SIFMA, ICI, and Deloitte
This document includes a detailed implementation schedule, interim milestones, and identified dependencies related to the move to a T+1 settlement cycle, including related to advisers’ obligations.
April 28, 2023
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
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
IAA Letter to SEC on Dealer Proposal
The IAA urged the SEC to exclude SEC-registered investment advisers and their clients, including private funds, from the proposed definition of dealer.
June 03, 2022
IAA, Joint Trades Letter Requesting Extension of Comment Period for Dealer Proposal
The IAA and other trade associations urge the SEC to extend the comment period for a proposal that would expand the definition of dealer to capture certain advisers and private funds.
May 20, 2022
IAA Letter to FINRA on Complex Products and Options
The IAA objected to FINRA’s questions on whether standards for complex products and options should apply to investment advisers because FINRA has no authority over investment advisers.
May 09, 2022
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