Based on member feedback, we are in the process of redesigning our Resource Center, as well as working on an improved search feature. In the meantime, if you need assistance finding a resource or would like to discuss an issue with a member of the legal team, please contact us at IAALegalTeam@investmentadviser.org.
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.
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.
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.
The IAA requested that the SEC make public the results of investor testing in connection with the standards of conduct proposals, and an extension of the comment period to incorporate results of the investor testing.
The IAA recommended that the SEC preserve the fiduciary duty standard under the Advisers Act, affirm that all who provide discretionary investment advice are subject to the fiduciary duty standard, adopt a new best interest standard of conduct for broker-dealers when making nondiscretionary investment recommendations, and prohibit those not subject to the Advisers Act from holding themselves out in a manner that implies a fiduciary relationship.
You are now leaving Investment Adviser Association
The IAA provides links to web sites of other organizations in order to provide visitors with certain information. A link does not constitute an endorsement of content, viewpoint, policies, products or services of that web site. Once you link to another web site not maintained by the IAA, you are subject to the terms and conditions of that web site, including but not limited to its privacy policy.
