Regulation: Alliance in Support of Independent Research

The Interstate Group was a founding member of the Alliance in Support of Independent Research. Members share a common interest in fostering a favorable regulatory environment in which independent research services may be furnished to the institutional investment community.

As issues arose, the Alliance submitted Comments to regulators in support of or in opposition to proposed regulation which would affect Independent Research, and was active in meeting with regulatory authorities, such as the SEC, DOL and Congress. Comments pertaining to several different issues are listed below with links to PDF copies of the reports. The Alliance is currently inactive as recent regulations support Independent Research.


09.23.2015-Alliance Comments to the International Organization of Securities Commissions (IOSCO) on Consultation Report 06/2015 Relating to Soft Commissions on Transactions -- Elements of International Regulatory Standards on Fees and Expenses of Investment Funds

10.10.2014-Alliance Comments to the Financial Conduct Authority on Discussion Paper 14/3 Relating to Bundled Brokerage and Soft Commission Arrangements -- Discussion on the use of dealing commission regime

04.02.2012-Alliance Comments to FINRA on Regulatory Notice 12-09 -- Debt Research Reports Rule

02.02.2010-Alliance Guidance to Asset Managers to Assist ERISA Plans in Reporting Information on Schedule C of DOL Form 5500 -- Disclosure Obligations Relating to Research/Commission Arrangements

10.01.2008-Alliance Comments to the SEC on File No. S7-22-08 -- Proposed SEC Commission Guidance Regarding the Duties and Responsibilities of Investment Company Boards with Respect to Investment Adviser Portfolio Trading Practices

05.16.2008-Alliance Comments to the SEC on File No. S7-10-00 - Proposed Amendments to Part 2 of Form ADV, Disclosure of Brokerage Practices

04.25.2008-Alliance Comments to the Department of Labor on Revisions to Annual Information Return, RIN1210-AB06 -Pertaining to Amendments to DOL Form 5500 Schedule C Regarding Research Arrangements

12.05.2006-Alliance Comments to Financial Services Authority on Consultation Paper 06/18 - Use of Dealing Commission

11.23.2005-Alliance Comments to the SEC on File No. S7-09-05 - Proposed Interpretive Release of Section 28e with Respect to Client Commission Practices

11.16.2004-Alliance Press Release Applauds NASD Mutual Fund Task Force Report Supporting Use of Independent Research by Mutual Fund Advisers

07.29.2004-Alliance Press Release Announced Opposition to the Mutual Fund Directors Forum's Call to End "Soft Dollar" Arrangements - MFDF Ignores Evidence that Research Arrangements Under the Section 28(e) Safe Harbor Benefit Mutual Fund Investors

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