WASHINGTON, D.C. (November 30, 2020) —The North American Securities Administrators Association (NASAA) announced today that its membership has voted to adopt a model rule that consolidates and updates several existing NASAA model rules regarding investment adviser policies and procedures, streamlining and simplifying the regulatory framework for state-registered investment advisers.

“Our goal with this consolidated and streamlined model rule is to help enhance the culture of investment adviser regulatory compliance to minimize conflicts and risks to better serve investors,” said Lisa A. Hopkins, NASAA President and West Virginia Senior Deputy Securities Commissioner.

The model rule would require investment advisers to establish, maintain, and enforce written policies and procedures that address: regulatory compliance, supervision, proxy voting, physical security and cybersecurity, business continuity and succession, code of ethics compliance, and the handling of material non-public information. In this way, the model rule will supplant and update two existing NASAA model rules, the NASAA Model Rule on Business Continuity and Succession Planning (April 13, 2015) and the NASAA Investment Adviser Information Security and Privacy Rule Model Rule (May 19, 2019). The proposal adopted by the NASAA membership also includes a compliance grid designed to help investment advisers develop and implement their own compliance policies and procedures.

The model rule and compliance grid were developed by project groups in the NASAA Investment Adviser Section, chaired by Indiana Securities Commissioner Alex Glass. The project groups determined that NASAA’s previous model rules related to investment adviser policies and procedures were incomplete and could be improved upon through a more comprehensive rewriting. The model rule adopted by the NASAA membership achieves that objective.

The model rule will be available for NASAA members to consider adopting in their own jurisdictions. A copy of the model rule is available on the NASAA website, here.