The IAA submitted a comment letter to the SEC reflecting our general views on the recent adviser outsourcing proposal. Our comments were developed with the input of our dedicated member workstream that is focusing on this proposal. We have significant concerns with the proposal and have urged the SEC not to move forward and instead to consider alternative approaches to achieve its goals.
Our initial take: the proposed rules are overly burdensome and prescriptive, fail to recognize how little leverage firms have over many service providers, and provide an unrealistic compliance period.
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