IAA Statement: The SEC’s Outsourcing Proposal
October 26, 2022
Our initial take on the SEC’s proposed new oversight requirements for services outsourced by investment advisers is that the proposed rules are overly burdensome and prescriptive and fail to recognize how little leverage firms have over many service providers. The proposal is also not adequately tailored to the range of firms it covers, including smaller advisers. It is also apparent that the SEC again has not appropriately considered the cumulative impact of its wave of new proposals on advisory firms of all sizes, nor has it provided sufficient time for meaningful feedback on these sweeping changes.