In a recent letter to the Securities and Exchange Commission, the American Bankers Association offered feedback on its recent registered investment adviser outsourcing proposal. Under the proposal, RIAs would be required to conduct certain due diligence, monitoring, recordkeeping and disclosure when engaging third parties to perform covered functions.
ABA urged the SEC to minimize the burdens of the proposal on banks and bank-affiliated RIAs, better align the proposal with existing bank third-party due diligence and oversight obligations and adopt specific recommendations if the SEC decides to proceed with a final rule.