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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Explanation of IAA Blue Sky/State Filing Summaries
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March 13, 2025
SEC-Registered Investment Adviser Firms State Notice Filing Guide
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March 13, 2025
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 Nevada’s Revised Proposed Fiduciary Duty Regulations
The IAA submitted a letter to Nevada expressing appreciation that its revised proposed regulations regarding fiduciary duty includes language clearly stating that the provisions of the regulation would only apply to an SEC Adviser as permitted by the National Securities Markets Improvement Act of 1996 (NSMIA).
August 02, 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 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