Use of Performance Fees

The Investment Adviser and Investment Company Committees of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a proposed exemption to allow investment advisers to charge fees based upon a share of capital gains upon or capital appreciation of a client’s account, Release No. IA-1682, File No. S7-29-97.  Although it supports the liberalization of the provisions relating to contractual provisions and disclosure, SIA suggests that given the lack of history of abuse regarding performance fee arrangements, it may not be necessary to raise the threshold net worth requirements, regardless of inflation.

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