Asset Management Advisory Committee

Washington D.C.

Thank you, Ed [Bernard].  And thanks to all the hard-working Committee members and panelists.  When Chairman Jay Clayton announced the formal establishment of the AMAC nearly two years ago, he charged it with helping “the Commission ensure that our regulatory approach to asset management meets the needs of retail investors and market participants at a time when the industry is evolving rapidly.”[1]  Over the next two years, the AMAC succeeded in addressing many of the pressing issues facing asset managers, and I for one have profited from the work and contribution each of you has made. 

Today’s agenda is in keeping with AMAC’s role to inform the Commission on pertinent matters affecting asset managers and their clients, and I am looking forward to hearing the presentations from the subcommittees on Private Investments and the Evolution of Advice.  The Private Investments Subcommittee’s final report will become an important source of information and insight as the Commission continues to look for ways to increase retail investor access to the vibrant private markets.  I hope remedying the diminishing retail investor options in these markets will be added to the Commission’s admittedly expansive agenda.  I am especially interested in hearing the update from the Small Advisers and Small Funds subcommittee.  Recognizing the important role that small advisers play in our markets and in the lives of our clients needs to be a key consideration in policy formulation.

One way to show our appreciation for the special challenges smaller advisers face is by taking the relatively simple step of amending our regulatory definition of just what a small adviser is for purposes of our regulatory analysis.  Currently, we define a small adviser as being a firm with assets under management of less than $25 million.[2]  As the presentation materials illustrate, almost 60% of advisers have assets under management of $100 million to $1 billion, most assets are managed by a small number of very large advisers,[3] and nearly 90% of all advisers have 50 or fewer non-clerical employees, with a median number of just eight employees.[4]  Regardless of what our rule says, these are small firms who feel keenly the cost of each additional regulatory requirement the Commission imposes.  Small advisers provide a bridge to prosperity, as they are engaged on a daily basis with retail investors in communities across the country, and it is incumbent on us to do all we can to encourage their growth and lower barriers.

I am looking forward to hearing what the subcommittees have to say, but I am even more excited to listen to the discussions that will follow.  Although I have not always agreed with AMAC’s recommendations, I have always benefited from hearing the thoughts of this dynamic group. 

[1] U.S. Securities and Exchange Commission, “SEC Announces the Formation of Asset Management Advisory Committee,” October 9, 2019, [Press release],   

[2] 17 CFR § 275.0-7. 

[3] “Presentation to the SEC’s Asset Management Advisory Committee,” Investment Adviser Association, Sept. 27, 2021, slide 7,  

[4] Id. slide 8.

Last Reviewed or Updated: Sept. 27, 2021