IAA Statement on Small Entity Proposal

The IAA highly commends the SEC for proposing to update its definition of small investment adviser and considering the IAA’s petition for rulemaking on this issue. We have long advocated that the SEC adopt a more realistic approach to how it evaluates the impacts of its rulemaking on smaller advisers. The proposal is an important step towards recognizing that the investment adviser industry is largely made up of small businesses that face different resource constraints from larger firms and that regulation should more appropriately take these factors into consideration. We look forward to reviewing the proposal and engaging with the SEC to ensure that the final rule accurately reflects the makeup of the adviser industry.