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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
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.
The IAA recommended that FINRA remove quantitative thresholds in the proposed exemptions for foreign employee retirement benefits plans and foreign investment companies.
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