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Comments on SEC Request for Comment on Information Providers Acting as Investment Advisers

The IAA submitted a comment letter in response to the SEC’s request for comment on when index providers, model portfolio providers, and pricing services (together, Information Providers) may be acting as investment advisers. We recommend that the SEC ensure that any action it takes does not result in increased costs and burdens that would create barriers to entry for or cause Information Providers to exit the market. The SEC should not impose a fiduciary duty on an Information Provider with respect to an investment adviser’s clients when that Information Provider has no relationship with and typically does not even know the identity of the adviser’s clients.

August 16, 2022

Keywords: SEC Investment Management

Categories & Topics: Account Operations, Operations

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