Notice of Request for Public Comment Regarding Proposed Model Rule for Investment Adviser Written Policies and Procedures Under the Uniform Securities Acts of 1956 and 2002
July 2, 2020

DOWNLOAD: Notice of Request for Public Comment
Deadline for Public Comment: August 1, 2020

The Investment Adviser Regulatory Policy and Review Project Group of the North American Securities Administrators Association, Inc. (NASAA) is seeking public comment on a proposed model rule to require investment advisers to establish, maintain, and enforce written policies and procedures tailored to the investment adviser’s business model.

Requiring state-registered investment advisers to establish, maintain, and enforce comprehensive written procedures is intended to facilitate compliance with state securities laws, rules, and regulations. Ultimately, an enhanced culture of investment adviser
regulatory compliance minimizes the effects of conflicts and other risks unique to investment advisers; minimizing the effects of these conflicts and risks serves to protect the investing public.

The Policies and Procedures Rule will require investment advisers to establish, maintain, and enforce policies and procedures that address compliance, supervision, proxy voting, physical and cyber security, a code of ethics (including holdings and transaction reports), handling of material non-public information, and business continuity and succession plans. An annual review of all
policies and procedures will be required, as will the appointment of a chief compliance officer who has the responsibility and authority to enforce the policies and procedures required by the rule.