Form ADV and Related Rules Under the Investment Advisers Act of 1940
SIFMA provides comments to the Securities and Exchange Commission (SEC) on Form ADV and related rules under the Investment Advisers Act of 1940, Release No. IA-2711; File No. S7-10-00. SIFMA still has concerns enumerated by the Securities Industry Association (SIA), a predecessor of SIFMA, on June 13, 2000 relating to providing more meaningful and digestible disclosure to investors and easing regulatory and administrative burdens on registered investment advisers. SIFMA also questions the desirability of moving forward with this proposal while basic frameworks for brokerage and investment advisory activities are being reassessed. SIFMA believes the proposal will be unfriendly to investors.