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SEC Proposal on Investment Adviser Performance Compensation

September 26, 2012
On July 11, 2011, CFP Board submitted a comment letter to the SEC (Missing Link), supporting its proposed rule amending the qualified client standard of Rule 205-3 under the Investment Advisers Act of 1940 to adjust for inflation the dollar amount tests every five years. CFP Board expressed the belief that the amended rule should help provide investors with the protections contemplated by Section 205 of the Advisers Act. Additionally, CFP Board supported the Commission's proposal to exclude the value of a client's primary residence from the net worth test, given that ownership of a home is not necessarily indicative of investment experience or sophistication, or the ability to assume the risks associated with performance fee arrangements.