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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
Comments on the Washington Administrative Code (WAC) Amendments to Investment Adviser Rules
The IAA raised concerns that several of the State of Washington’s proposed rules for investment advisers were written to apply to SEC-registered advisers, which raises preemption issues.
January 08, 2019
Comments on Regulation Best Interest, Form CRS, and Advisers Act Fiduciary Duty Interpretation
The IAA supported the SEC’s efforts to extend fiduciary principles to all financial professionals. Regarding proposed Regulation Best Interest, the IAA raised concerns about the narrow scope and application of the rule. The IAA recommended investor testing and streamlining of proposed Form CRS and discussed the need for a more principles-based approach and certain clarifications in the fiduciary duty interpretation.
August 06, 2018
Comments on the SEC’s Request for Comment on Enhancing Investment Adviser Regulation
The IAA strongly urged the SEC not to impose broker-dealer regulation on investment advisers and discussed the significant differences between investment adviser and broker-dealer business models.
August 02, 2018
Remarks at SEC Investor Advisory Committee Meeting on Regulation Best Interest and Form CRS
Karen Barr, president & CEO of the IAA, commended the SEC for taking action to strengthen the standard of conduct for broker-dealers. She discussed the IAA’s concerns about the scope of proposed Regulation Best Interest. Regarding proposed Form CRS, the IAA has significant concerns about the potential for investor confusion and supports investor testing.
June 14, 2018
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