ABA to SEC: Minimize concerns on banks, affiliates from financial investment consultant contracting out proposition

In a current letter to the Securities and Exchange Commission, the American Bankers Association used feedback on its current authorized financial investment consultant contracting out proposition. Under the proposition, RIAs would be needed to carry out specific due diligence, tracking, recordkeeping and disclosure when engaging 3rd parties to carry out covered functions.

ABA prompted the SEC to lessen the concerns of the proposition on banks and bank-affiliated RIAs, much better line up the proposition with existing bank third-party due diligence and oversight responsibilities and embrace particular suggestions if the SEC chooses to continue with a last guideline.