Investment Management

FSR advocates on behalf of members that provide investment products and services to individual and institutional investors, businesses, not-for-profit organizations, and governments (federal, state, and local); manage investments for themselves or their clients; provide financial, investment, or advisory services; and underwrite, deal-in, or make markets in capital markets financial instruments. 

Current Investment Management Priorities: 

  • Fiduciary Duties and Standards of Care
  • Systemic Risk Review of Asset Management
  • Retirement Planning and Saving
  • Regulating Municipal Securities Disclosures
  • Investment Funds Regulation
  • Retail Securities Issues
  • U.S. Securities Market Structure, Resiliency and Oversight

FSR Statement on State of the Union Address

January 29, 2014

“It is encouraging the President called for action on the critical issue of housing finance reform,” said Tim Pawlenty, CEO of FSR. “Reforming Fannie and Freddie so that taxpayers are no longer on the hook is critical and the time to act is now.”

Death Master File Department of Commerce Letter, 1/28/14

January 28, 2014

Under section 203 of the Act, the Department of Commerce is directed not to disclose information on the Death Master File (“DMF”) to any person unless that person has been certified under a program established by the Department. In order to be certified, a person must meet certain conditions, including having a legitimate fraud prevention or business purpose for needing access to the DMF information. We are certainly supportive of the important objectives of this provision, i.e., to prevent fraudulent and other abusive use of DMF information. We are also very appreciative that Congress protected legitimate use of DMF information.

Letter re: Pay Ratio Disclosure, Securities Act Release No. 9,452 – 12/2/13

December 2, 2013

The SEC proposed that certain companies disclose the ratio of the compensation of their principal executive officer to that of all employees in the company’s annual report, proxy or information statement, or registration statement that requires executive compensation disclosure pursuant to Item 402 of Regulation S-K. While FSR supports meaningful disclosure, we believe that the disclosure required in this instance will not be materially helpful to investors, and the Commission should seek reconsideration of the Congressional mandate in the Dodd-Frank Wall Street Reform and Consumer Protection Act. In our comments, FSR also recommends certain adjustments or alternative approaches that will further enhance the Commission’s flexible approach to identifying the median employee as reflected in the proposed amendments to Item 402, which would implement the so-called “Pay Ratio Rule” mandated pursuant to section 953(b) of the Dodd-Frank Act.

Letter re: OFR, “Asset Management and Financial Stability” – 11/1/13

November 1, 2013

The Office of Financial Research of the Department of the Treasury prepared a study entitled, “Asset Management and Financial Stability” at the request of the FSOC. The Council commissioned the Study in order to “inform its analysis of whether—and how—to consider [asset management] firms for enhanced prudential standards and supervision” within the meaning of section 113 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. FSR has several substantive concerns with the Study. First, the failure to adopt a sound methodology for conducting the Study has resulted in a report that lacks rigor, balance and perspective. Second, the Study appears to be flawed in its analyses of (i) asset management firms as sources of systemic risk, (ii) redemption risk, (iii) asset management firms’ connections with the financial industry, (iv) the principal-agent relationship between asset managers and their clients as a source of systemic risk, and (v) the use of leverage. Third, the Study reflects a fundamental misunderstanding of the asset management industry, how asset management firms operate, and the expectations of investors in the capital markets. In particular, the Study fails to appreciate the fact that investors will take on greater risk in order to receive the potential for greater return. Fourth, the Study gives insufficient weight to the comprehensive regulatory régime imposed on asset managers and the industry by several U.S. regulatory agencies, including the Securities and Exchange Commission, and non-U.S. regulatory agencies, particularly with respect to the new regulatory requirements imposed since the Dodd-Frank Act. Finally, the Study fails to appreciate the important role that asset managers play as agents acting on behalf of millions of individual and institutional investors who participate in U.S. capital markets and the contributions that asset managers make to the financial stability of the United States.

Fed’s Yellen seen winning Senate approval after vigorous debate

October 9, 2013

Tim Pawlenty, a former Republican Governor of Minnesota who sought his party’s nomination for president in 2011, said she was “a talented economist who will bring a wealth of experience to the job,” in a statement on behalf of the Financial Services Roundtable, of which he is president and chief executive.

Letter re: Regulation Systems Compliance and Integrity, Exchange Act Release No. 69077 – 6/5/13

June 5, 2013

If adopted, Regulation Systems Compliance and Integrity would represent the Securities and Exchange Commission’s first foray into the direct regulation of technology and systems. It would impose obligations on specified entities and their personnel concerning particular systems utilized in the conduct of their business. Reg SCI would accomplish its goals by requiring a combination of “reasonably designed” policies and procedures; corrective action in response to issues; and review, reporting and notification protocols. The proposed rule also includes a safe harbor from liability, which raises many questions about the standard of liability to which applicable entities and personnel would be held under proposed Reg SCI. Given the complexity of the relevant technologies and the interconnectivity of the various systems, FSR opposes a strict liability standard because it is unworkable. The proposed safe harbor also would result in “finger-pointing” rather than productive dialogue when technology failures inevitably occur, and runs the risk of becoming the de facto yardstick for measuring Reg SCI compliance.


April 17, 2013

Tim Pawlenty, president and CEO of the Financial Services Roundtable, said a recent survey conducted by his group found respondents less worried about economic conditions as barriers to growth than the “cumulative effect of regulations. … We look at lack of clarity and certainty [with respect] to the timing, nature, and magnitude” of multiple rules initiatives.