1. SROIIA does not advocate for SRO regulation

SROIIA understands that advisers prefer that the SEC remain as the regulatory body over the industry and we do not oppose such an outcome. In fact, we do not advocate for the appointment of a self-regulatory organization. We do, however, advocate for authorizing more than one SRO if Congress determines that regulatory oversight should be passed to SROs. Why? Because we believe that in such an event, advisers should have an option as to who their regulator will be, and we intend on providing the option of having a SRO tailored to, and managed by, the industry.

2. SROIIA is not attempting to impose new regulations on advisers

We do not promote the imposition of more regulations; rather, we promote better enforcement of existing regulations. How? By streamlining the enforcement branch of the SRO and creating efficiency in processes using technology. In our opinion, it is left up to legislators, the Commission, or the industry (through the SRO) to determine whether or not new regulations should be adopted.

3. SROIIA believes in self-regulation

Our goal is to establish an IA-SRO model that will serve as a placeholder for adviser self-regulation in the event Congress moves forward with SRO legislation. It is not up to us (SROIIA and advisers) how Congress will deal with the regulatory landscape of the industry, but it is up to us how prepared the industry will be to regulate itself. Without an established SRO model, investment advisers will be forced to play catch-up in building a satisfactory SRO model that could pass SEC scrutiny, with an unlikelihood of success.