The Asset Management Group of SIFMA (SIFMA AMG) and the Investment Adviser Association (IAA) provide comments to the Securities and Exchange Commission (SEC) the study published by the Office of Financial Research of the U.S. Department of Treasury (OFR) and commissioned by the Financial Stability Oversight Council (FSOC), Asset Management and Financial Stability.

The groups believe that effective regulation can only be based on rigorous analysis. Unfortunately, they also found the study lacks evidence of rigorous analysis, and therefore, the groups believe that it does not reflect an accurate or effective understanding of the role of asset managers, the relationship between asset managers and the invest products they offer, and the factors that link asset managers and investment products to potential financial market distress.