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Joint trades letter supporting legislation to improve guardrails and transparency in the designation process for systemically important financial institutions (H.R. 3682, the Financial Stability Oversight Council Improvement Act of 2025).
October 29, 2025
IAA and Trades Encourage FSOC to Return to an Activities-Based Approach
Joint trades letter encouraging FSOC to restore the 2019 guidance governing the designation of nonbank financial institutions as SIFIs.
July 14, 2025
Comments on FSOC Guidance Regarding Supervision and Regulation of Nonbank Financial Companies
The IAA supported FSOC’s proposed activities-based approach to identify, assess, and address potential systemic risk in nonbank financial companies. The IAA also argued that the fundamental nature of asset management does not pose systemic risk because it is an agency business, and that asset managers are subject to robust regulation.
May 10, 2019
The IAA explained that asset managers do not present systemic risk and stress testing is unnecessary for investment advisory firms due to the nature of their business. The IAA also discussed the need to review, modernize, and streamline certain regulations under the Advisers Act, and the need to avoid overlapping regulation by the SEC and CFTC.
August 15, 2017
SEC Proposes Rules on BCP and Transition Plans
Compliance Issues for Advisers to Private Funds
May 30, 2017
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