The Leading Advocate for Portfolio Diversifying Investments

The IPA is the leading voice on critical legislative and regulatory issues affecting the Portfolio Diversifying Investments (PDI) industry. Our Policy Advocacy Committee coordinates the resources of the IPA and its members to create opportunities for the advancement of IPA objectives via the regulatory and political process.

Through policy advocacy, we communicate directly with state and federal lawmakers and industry regulators, educating them about the distinct positive attributes of PDIs.

The IPA Policy Advocacy Committee regularly monitors and develops political action plans.

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Policy Advocacy That Advances the Industry

The IPA coordinates the resources of its members to create opportunities for the advancement of industry objectives through established regulatory and political processes. We continue to raise awareness of PDIs to legislators and regulatory officials alike, clearly communicating the distinct attributes our products can offer the investing public.

The IPA is currently tracking progress on a range of critical issues, including:

Securities Law Reform

Securities Law Reform

The IPA believes securities law reforms can safely increase capital formation and spur economic growth, while simultaneously maintaining investor protections. We urge members of Congress to consider legislation that would provide BDC Modernization, Accredited Investor Modernization and changes to section 12(g).

Download Issue Brief

Comprehensive Tax Reform

Comprehensive Tax Reform

The IPA supports comprehensive tax reform for corporations and individuals that will grow our economy and American jobs. Congress must preserve Section 1031 Like-Kind Exchanges to allow deferral of capital gains on real estate investments; Pass Through Corporations should be treated equally and debt interest should continue to be deductible.

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DOL Fiduciary Standard

DOL Fiduciary Standard

The IPA is requesting the Department of Labor to further delay the effective date of the Fiduciary Duty rule to allow sufficient time to conduct the review required by the President. An additional 180 days is the minimum time needed to complete this important review. Second, Congress needs to act to force the DOL and the Securities and Exchange Commission (SEC) to act jointly to prescribe a harmonized best interest standard that will protect all investors across all types of investments, in a workable manner that safeguards access to quality financial advice.

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A Collaborative Approach to Industry Regulation

The IPA’s Legal and Regulatory Affairs Committee reviews and evaluates regulatory issues that may affect the business objectives of our members. It seeks to educate industry participants about trends and issues and as appropriate, prepare responses and/or position papers by the IPA that have broad industry acceptance. The Committee continues to work closely with our regulatory leaders at NASAA, FINRA and the SEC. Recent issues include:

NASAA Revised REIT Guidelines

The North American Securities Administrators Association (NASAA) is in the process of revising its REIT Guidelines. The IPA supports NASAA in updating the guidelines at this time, and  submitted comments on behalf of the industry in September 2014.  It is our hope that this open exchange of ideas will ultimately ensure investor protection while encouraging capital formation by promoting coordination and uniformity among the various state and federal statutes.

Changes to Customer Account Statements (Amendments to FINRA Rule 2310, NASD 2340)

New FINRA regulations effective on April 11, 2016  require a modification to the way REITs or BDC investments are reflected on customer account statements. The IPA worked collaboratively with FINRA and the SEC to ensure that this new rule provides enhanced clarity for investors, but also provides a sensible transition to the next generation of Portfolio Diversifying Investment (PDI) products. In addition to the establishment of Valuation Guidelines and continued efforts to develop Uniform Performance Metrics, the IPA remains committed to supporting product innovation that serves as a catalyst to constructively grow the industry.

Advancing Industry Best Practices and Guidelines

The IPA is committed to providing Best Practice Guidelines on significant industry issues. Best Practice Guidelines are a set of voluntary best practices designed to advance the Portfolio Diversifying Investments (PDI) industry.

A guideline development process has been established to ensure that IPA members, experts, interested industry participants, and relevant agencies inform the deliberative process and have input in the final content of each guideline. During the Guideline Development Process, pending guidelines will be posted on the members only section of the IPA website for members to see what is under development. A Comment section is available on the website to provide an opportunity for members of the IPA to provide input and comments during the development stages. The Advisor team of each guideline will receive comments and respond accordingly

•  REIT Sales Practice Guidelines (expected to be issued in 2018)
•  BDC Performance Guidelines (April 2015)
•  Valuation of REITs (April 2013)
•  Modified Funds From Operations – MFFO (November 2010)

Comment Letters

Numerous IPA Committees regularly review and evaluate regulatory issues that may affect our industry. Self-Regulatory Organizations (SROs), regulatory bodies and industry organizations, such as FINRA, the SEC, NASAA, etc. are monitored regularly for new rules and guideline changes. From time to time the IPA will issue a comment letter on behalf of the membership. The main purpose of the comment letter is to assist/educate the issuing regulatory body or organization when it is considering changing rules, procedures, guidelines or best practices.

Comment Letters