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

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.

Letter re: Proposed Recommendations Regarding Money Market Mutual Fund Reform, 1/18/13

January 18, 2013

FSR and its members appreciate the work of the Financial Stability Oversight Council and share its goal of seeking to ensure that money market funds remain a convenient and cost-effective means of pooling investments in money market instruments. We respectfully submit that the Council’s Proposed Recommendations to reform MMFs are premature. As the Council itself recognizes, the Securities and Exchange Commission is best positioned to assess alternative approaches to MMF reforms and to implement any additional reforms.