Comment Letters

IAA Comments & Statements


This section includes comment letters, statements, and other IAA correspondence relating to major issues affecting the investment management industry.

Current IAA Comments & Statements

2019

Date

Agency

Topic

October 18, 2019
SEC
Accredited investor definition & securities offering exemptions
September 13, 2019
CFTC, DSIO
Interplay of exemptions for offshore pools
August 29, 2019
SEC
FINRA Rule 5130, initial public offerings
August 9, 2019
SEC
Pay-to-play and smaller advisers
August 8, 2019
Australian Securities & Investments Commission (ASIC)
Foreign Financial Service Providers (FFSPs)
July 25, 2019
Massachusetts Securities Division
Fiduciary & preemption
June 14, 2019
New Jersey Bureau of Securities
Fiduciary & preemption
May 10, 2019
FSOC
Activities-based approach and systemically important financial institution (SIFI) entity determination
May 2, 2019
SEC
Fund of funds arrangements
March 11, 2019
SEC, CFTC, OCC, Federal Reserve Board, and FDIC (Volcker Agencies)
Volcker rule (name-sharing restrictions)
March 8, 2019
Maryland House of Representatives
Fiduciary & preemption
March 8, 2019
Maryland Senate
Fiduciary & preemption
March 1, 2019
Nevada Securities Division
Fiduciary & preemption
January 24, 2019
President Trump and Congress
Government shutdown
January 10, 2019
Congress
Portable Retirement and Investment Accounts (PRIAs)
January 8, 2019
Washington State Department of Financial Institutions
State rules & preemption

2018

Date

Agency

Topic

December 31, 2018
CFA Institute
GIPS 2020
December 31, 2018
SEC
Proxy voting
December 27, 2018
SEC
Custody rule and small entities
December 21, 2018
CFTC
Swap execution facilities (SEF) proposal (extension)
December 17, 2018
CFTC
Registration and compliance requirements for CPOs and CTAs (Project KISS)
December 13, 2018
New Jersey Bureau of Securities
Fiduciary & preemption
December 6, 2018
Senate Banking Committee
Proxy voting
December 4, 2018
SEC
Form CRS investor testing
November 14, 2018
Australian Securities & Investments Commission (ASIC)
Licensing of foreign financial services providers
October 16, 2018
SEC, CFTC, OCC, Federal Reserve Board, and FDIC (Volcker Agencies)
Volcker rule (banking entity, trading account, and covered fund definitions)
August 6, 2018
SEC
Standards of conduct (Reg BI, Form CRS, fiduciary duty)
August 2. 2018
SEC
Additional investment adviser regulation (financial responsibility regulations, account statements, and federal licensing and continuing education)
July 10, 2018
House Financial Services Committee
Investment Adviser Regulatory Flexibility Improvement Act
July 5, 2018
UK FCA
Proposed guidance for Authorised Fund Managers (AFMs) on communicating fund objectives and investment policies in key information documents (active management)
June 14, 2018
SEC Investor Advisory Committee
Proposed Reg BI and proposed restriction on the use of certain names or titles
May 25, 2018
SEC
Requesting extension of comment period on standards of conduct proposals to incorporate the results of investor testing
May 18, 2018
SEC
Investment company liquidity disclosure
April 25, 2018
Treasury
Report on Regulations Impacting Nonbank Financial Institutions, Technology, and Innovation (use of technology: digital advice, distributed ledger technology, cloud services, third parties, and data aggregation)
March 7, 2018
SEC Division of Investment Management and OCIE
Inadvertent custody guidance update
January 22, 2018
European Commission
Sustainability

2017

Date

Agency

Topic

December 1, 2017
Legal Entity Identifier (LEI) Regulatory Oversight Committee
Fiduciary & preemption
November 22, 2017
CFA Institute
GIPS guidance statement on overlay strategies
October 3, 2017
EU regulators
Uncleared swap variation margin requirements for physically-settled FX contracts
October 2, 2017
Nevada Securities Division
Fiduciary & preemption
September 29, 2017
CFTC
Simplifying CFTC rules (Project KISS)
September 21, 2017
OCC
Volcker rule (proprietary trading, banking entity, covered funds and name-sharing prohibition)
August 31, 2017
SEC Chairman
Standards of conduct (fiduciary duty)
August 15, 2017
Treasury
Core Principles for Regulating the United States Financial System (opposing prudential regulation, reiterating recommendations made to the SEC and CFTC)
August 7, 2017
DOL
DOL fiduciary rule and prohibited transaction exemptions
July 28, 2017
Treasury
Review of regulations (reiterating anti-money laundering (AML) and FBAR comments)
July 16, 2017
CFA Institute
GIPS 2020
May 10, 2017
SEC Chairman
Welcome letter to SEC Chairman Jay Clayton highlighting policy issues, including retrospective review of SEC rules, oversight, and standards of conduct/fiduciary duty
May 1, 2017
CFTC
Regulation Automated Trading
April 17, 2017
DOL
DOL fiduciary rule
April 14, 2017
Senate Banking Committee
Small entities
March 20, 2017
CFTC
Recordkeeping Rule 1.31
February 21, 2017
SEC
SEC no-action letter to the IAA re Standing Letters of Authorization (SLOAs)
January 24, 2017
CFTC, Federal Reserve Board, OCC, UK FCA, European Commission, and other regulators
Uncleared swap margin requirements – request for transitional relief from variation margin implementation

2016

Date

Agency

Topic

December 5, 2016
DOL
Annual reporting and disclosure (Form 5500)
September 21, 2016
FSB
Proposed policy recommendations to address structural vulnerabilities from asset management activities (SEC rulemaking, measuring leverage in funds)
September 14, 2016
FinCEN
Anti-money laundering (AML) and suspicious activity reports (SARs)
September 6, 2016
CFTC
Regulation 3.10(c) exemption from registration for certain foreign persons
September 6, 2016
FSOC
Business continuity and transition plans
Aug. 22, 2016
CFPB
Arbitration agreements
Aug. 18, 2016
SEC
Use of derivatives by registered investment companies and business development companies
July 22, 2016
SEC
Incentive-based compensation arrangements
June 29, 2016
SEC
Accredited investor definition
June 13, 2016
House Financial Services Committee
Investment Advisers Modernization Act of 2016
May 9, 2016
FinCEN
FBAR
April 29, 2016
CFA Institute
GIPS guidance statement on broadly distributed pooled funds
March 28, 2016
SEC
Use of derivatives by registered investment companies and business development companies
March 16, 2016
CFTC
Regulation Automated Trading
February 2, 2016
CFTC
Regulation 3.10(c)(3)(i) (request for registration relief for non-U.S. CPOs and CTAs that cannot comply with the swaps clearing condition)
January 27, 2016
CFTC
Form CPO-PQR FAQs