Comments on Proposed Rule: Adviser Business Continuity and Transition Plans

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Date Received
Date Letter Type Commenter Name
Meeting with SEC Officials Memorandum from the Office of the Chairman regarding a June 8, 2017, meeting with representatives of the Investment Company Institute
Public Comment Stuart J. Kaswell, Executive Vice President & Managing Director, General Counsel, Managed Funds Association
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a September 26, 2016, meeting with representatives of the Managed Funds Association
Meeting with SEC Officials Memorandum from the Office of the Chair regarding a September 26, 2016, meeting with representatives of the D.E. Shaw Group, Millennium Management LLC, Davidson Kempner Capital Management, and the Managed Funds Association
Public Comment Mike Rothman, President, North American Securities Administrators Association, Inc. (NASAA)
Public Comment Kurt N. Schacht, CFA, Managing Director, Standards and Advocacy, and Linda L. Rittenhouse, Director, Capital Markets Policy, CFA Institute
Public Comment John R. Gidman, President, Association of Institutional INVESTORS
Public Comment Barbara Novick, Vice Chairman, BlackRock, Inc.
Public Comment Brett Palmer, President, Small Business Investor Alliance (SBIA), Washington, District of Columbia
Public Comment BRG Fund Management Services, LLC, New York, New York
Public Comment Brian S. Hamburger, JD, CRCP, President and Chief Executive Officer, and Daniel A. Bernstein, JD, Chief Regulatory Counsel; MarketCounsel, LLC, Englewood, New Jersey
Public Comment Chris D. McIsaac, Managing Director, Planning and Development, The Vanguard Group, Inc., Valley Forge, Pennsylvania
Public Comment David B. Smith, Jr., Executive Vice President and General Counsel, Mutual Fund Directors Forum, Washington, District of Columbia
Public Comment David T. Bellaire, Esq., Executive Vice President & General Counsel, Financial Services Institute
Public Comment Gary A. LaBranche, FASAE, CAE, President & CEO, Association for Corporate Growth
Public Comment Gregory B. Cade, Director of Government Affairs, National Fire Protection Association
Public Comment Jason Mulvihill, General Counsel, American Investment Council
Public Comment Joe Delaney
Public Comment John Gebauer, President, National Regulatory Services, Lakeville, Connecticut
Public Comment John M. Zerr, Senior Vice President, Invesco Ltd.
Public Comment Marc Bryant, Senior Vice President and Chief Legal Officer, Fidelity Management & Research Company
Public Comment Mark Heckert, Managing Director, Interactive Data Pricing and Reference Data LLC, an Intercontinental Exchange Company, New York, New York
Public Comment Paul W. Wojcik, Chief Risk Officer, and Jonathan D Siegel, V.P. and Senior Legal Counsel, T. Rowe Price Associates, Inc., Baltimore, Maryland
Public Comment Richard Foster, Financial Services Roundtable, Washington, District of Columbia
Public Comment Robert C. Grohowski, General Counsel, Investment Adviser Association, Washington, District of Columbia
Public Comment Stefan M. Gavell, Executive Vice President and Head of Regulatory, Industry and Government Affairs, State Street Corporation
Public Comment Stuart J. Kaswell, Executive Vice President & Managing Director, General Counsel, MFA, and Jiří Król, Deputy CEO, Global Head of Government Affairs, AIMA
Public Comment Thomas Quaadman, Executive Vice President, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce, Washington, District of Columbia
Public Comment Michael R. Granito, Senior Vice President, Chief Risk Officer, Federated Investors, Inc.
Public Comment Timothy W. Cameron, Esq., Head, and Lindsey Weber Keljo, Esq., Vice President and Assistant General Counsel, Asset Management Group, Securities Industry and Financial Markets Association, Washington, District of Columbia

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-13-16
Release Number
IA-4439
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