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The IAA has filed a comment letter in support of FINRA’s proposed rule on investment adviser activities of broker-dealers’ associated persons conducted at an investment adviser that’s not affiliated with the broker-dealer. As recommended by the IAA, the rule would exclude these advisory activities — which are outside of FINRA’s jurisdiction — from broker-dealer supervision and recordkeeping requirements.
The IAA urges FINRA to reconsider its outside activities rule proposal to exclude oversight of investment adviser activities, which are not subject to FINRA’s jurisdiction
One of the core responsibilities of defined contribution plan fiduciaries is selecting the investment options that will be available to participants in the plan. This paper summarizes the principles governing the exercise of that responsibility in 50 years of law, regulation, regulatory guidance, and court decisions.
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).
To allow members sufficient time to fully implement the Department of Labor’s fiduciary exemption, the IAA requested an extension of the DOL’s non-enforcement policy, set to expire on December 20, 2021.
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