On August 7, MFA and AIMA submitted a joint comment letter to the SEC in response to the proposed areas of enhanced investment adviser regulation in the SEC’s Interpretation Regarding Standard of Conduct for Investment Advisers. In our letter, we explained that we do not believe it is necessary or appropriate for the SEC to propose or adopt regulations mandating net capital, fidelity bonding or similar requirements for investment adviser representatives, account statement delivery requirements, or federal licensing and continuing education requirements for investment advisers. With respect to the potential net capital requirements in particular, we believe that such requirements would offer little in the way of investor protection and impose significant burdens on investment advisers, which are likely to increase costs on or limit the options available to clients.
