In a recent speech at the North American Securities Administrators Association (“NASAA“) annual conference, Texas Securities Commissioner, Denise Voigt Crawford who is the incoming NASAA President, revealed that the SEC might raise the asset under management (“AUM“) threshold for SEC registration of investment advisers from $25 million to $100 million, and NASAA supports such a change.
The NASAA President explained that “…the current dividing line between federal and state regulation of investment advisory firms is $25 million of assets under management. The SEC might increase this to $100 million of assets under management. Given the difficulty the SEC has in examining such a large number of investment advisory firms, I think this is a good idea. NASAA has endorsed such a change and will work closely with the SEC to make this happen.”
For those smaller SEC registered investment advisers that have voiced concerned about the burden of the proposed SEC rule requiring an annual surprise audit by a public accounting firm, such a change is likely to be well received by many investment advisers, especially since NASAA has indicated that it doesn’t believe the surprise audit requirement is necessary for investment advisers deemed to have custody solely due to automatic fee deduction.