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"The first trend I’d note is the sheer growth over many years of the private funds field. In aggregate, they grew more than 10 percent ...
"My reservations stem from the breadth of the rule and the likelihood that it will spawn more consumer notices than are helpful"
"Rapid technological change is now the norm and more frequent cybersecurity incidents and data breaches add additional risks that warrant Commission action to ensure that ...
"The final amendments do not require a financial institution to enter into a contract with its service providers to deliver data breach notices .... This ...
"Investments in alternative asset classes are growing .... This growth means that investors are increasingly allocating assets to unregistered funds by investing directly through products ...
Nearly 80% don’t showcase specific investment advice. Advisers have not embraced sharing testimonials (92% don’t), endorsements (85% don’t) or third-party ratings (83% don’t)
"Under these amendments, covered firms will be required to notify customers of breaches that might put their personal data at risk"
"It is difficult to envision a money laundering concern that should be addressed with these activities, and it is unreasonable to require advisers to implement ...
"The proposed rule is designed to make it more difficult to use false identities to establish customer relationships with investment advisers"
"The fundamental problem is that we are not examining investor protection, efficiency, competition, and capital formation in a steady state ecosystem. Rather, it is fast-changing, ...