In its Annual Report on state-registered investment advisers, the North American Securities Administrators Association ("NASAA") highlighted its major regulatory undertakings during 2020 and outlined challenges faced by the investment adviser industry and state securities regulators as a result of the pandemic.
NASAA touted its adoption of (i) a model rule for implementing a continuing education program for investment adviser representatives, and (ii) a model rule and accompanying compliance grid to help investment advisers enhance a "culture of compliance" and identify issues to be addressed in policies and procedures. NASAA also provided project group reports concerning (i) cybersecurity and technology, (ii) operations, (iii) regulatory policy and review, (iv) resources and publications, and (v) training.
NASAA also reviewed pandemic-related developments concerning business continuity and succession planning, cybersecurity and the protection of client information, and supervision challenges for investment advisers.
NASAA recommended that investment advisers:
- bolster their business continuity and succession plans;
- undertake an assessment of their operations to determine the potential risks and vulnerabilities posed by remote working; and
- seek guidance from their state securities regulators concerning activities that are required to be included in their firms' written supervisory procedures.
Primary Sources
- NASAA Press Release: NASAA Releases Annual Report on State-Registered Investment Advisers
- NASAA Annual Report: 2021 Investment Adviser Section Annual Report
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