Proposals Related to Investment Advisers Operating in Multiple States

The Investment Adviser Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a proposed exemption for investment advisers operating in multiple states and revisions to other rules implementing amendments to the Advisers Act of 1940, Release No. IA-1681, File No. S7-28-97.  The proposals would make investment advisers who do not manage assets in excess of $25 million, but would be required to register in 30 or more states, eligible for federal registration.  The proposals would also modify the definition of the term “Investment Adviser Representative” to expand the circumstances under which essentially institutional advisers, who handle only a limited number of “accommodation” and/or sophisticated investor accounts, would be exempt from state registration.  SIA offers its support for the proposals.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.