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





October 5, 2021 | PDF

House Financial Services Committee

OIA Improvement Legislation

October 1, 2021 | PDF


Investment Adviser Digital Engagement Practices and the Use of Technology to Develop and Provide Investment Advice

September 23, 2021 | PDF


Exchange Act Rule 15c2-11 and the Fixed Income Markets

September 23, 2021 | PDF


Requesting extension on compliance with Fiduciary Exemption

July 29, 2021 | PDF

 Australian Treasury

Foreign Financial Service Providers (FFSPs)

June 11, 2021 | PDF


Public Input on Climate Change Disclosures

May 17, 2021 | PDF


Welcome letter to SEC Chair Gary Gensler highlighting policy issues, including standards of conduct/fiduciary duty, sustainable investing, DEI, e-delivery, proxy voting, custody, and the pay-to-play rule

May 13, 2021 | PDF


Custody (non-DVP)

April 19, 2021 | PDF

 US House Financial Services Committee

Diversity and Inclusion Data Accountability and Transparency Act

April 11, 2021 | PDF SEC

Cross Trading

February 1, 2021 | PDF
Federal Trade Commission

Hart-Scott-Rodino Proposal on Aggregation

January 28, 2021 | PDF
European Commission

Delegation & Sustainability





October 19, 2020 CFA

ESG Consultation Paper

October 5, 2020 DOL

Proxy Voting Proposal

September 29, 2020 SEC

Form 13F

September 25, 2020 DOL

Requesting extension of comment period on proxy proposal

August 26, 2020 Prudential Regulators

Initial Margin for Uncleared Swaps

August 19, 2020 SEC


August 11, 2020 CFTC

Exemption for Offshore Pools

August 6, 2020 DOL

Fiduciary Proposal

August 5, 2020 CFTC

Initial Margin for Uncleared Swaps

July 30, 2020 DOL

ESG Proposal

July 21, 2020 SEC

Good Faith Determinations of Fair Value

July 20, 2020 SEC


July 20, 2020 DOL Requesting extension of comment period on ESG proposal
June 15, 2020 CFTC        Form CPO-PQR
June 12, 2020 New York State Department of Law        Investment Adviser Representative Regulations
June 1, 2020 SEC Exempt Offerings
May 1, 2020 OMB DOL E-Delivery Rule
April 30, 2020 SEC Derivatives and Sales Practice Rules
April 16, 2020 NASAA Investment Adviser Representative Continuing Education Program
April 1, 2020 SEC, CFTC, OCC, Federal Reserve Board, and FDIC (Volcker Agencies) Volcker rule (covered funds seeding period extensions, fund life cycle events, real estate funds)
March 25, 2020 BCBS and IOSCO Initial Margin for Uncleared Swaps Implementation
March 24, 2020 Congress Advisory fee deductibility
March 23, 2020 Oklahoma Department of Securities Fiduciary & preemption
March 20, 2020 Congress Coronavirus: Retirement Plans & Savers
March 18, 2020 SEC  Accredited Investor and Qualified Institutional Buyer (QIB)
February 10, 2020 SEC  Advertising & Solicitation
February 3, 2020 SEC  Proxy Advice proposal
January 6, 2020 Massachusetts Securities Division Fiduciary & preemption





December 18, 2019 House Ways and Means Committee, Senate Finance Committee 20 percent tax deduction for pass-through businesses
November 27, 2019 SEC Investment Company Exemptive Applications
November 22, 2019 DOL Electronic Disclosure
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





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 Authorized 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





December 1, 2017 Legal Entity Identifier (LEI) Regulatory Oversight Committee Legal Entity Identifier
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 Record keeping 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