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IAA Petitions SEC to More Accurately Consider Impact of Regulations on Smaller Advisers

As part of the IAA’s ongoing advocacy on behalf of smaller advisers, we submitted a rulemaking petition to the SEC to require the agency to adhere to its statutory obligations to accurately analyze the impact of its regulations on smaller advisers and consider less onerous alternatives.

September 14, 2023

Keywords: Advocacy, Congress, Small Entity

Categories & Topics: Congress, Industry Trends, Industry-Level

Comments on Proposed Cybersecurity Rules for Advisers

We recommend changes to proposed cybersecurity rules that would require investment advisers to adopt and implement written cybersecurity policies and procedures with specified elements, report significant adviser cybersecurity incidents to the Commission, disclose significant adviser cybersecurity risks and incidents to clients, and maintain related books and records.

April 11, 2022

Keywords: Advocacy, Cybersecurity, SEC

Categories & Topics: Compliance, Cybersecurity/Privacy

SEC Form 13F Re-Proposal

The IAA commented on the SEC’s re-proposal of amendments to Form 13F that (i) additional identifying information in Form 13F is not needed, (ii) the SEC could provide managers with flexibility to choose an alternative identifier to a CUSIP and should study holistically issues raised by requiring the use of licensed security identifiers, and (iii) the SEC should not make technical amendments to the well-established rounding conventions or how a security’s value is reported.

December 17, 2021

Keywords: 13F, Advocacy, CUSIP

Categories & Topics: 13F, Reporting

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