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ADVOCACY

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Comment Letters

comment letters

Addressing critical legislative and regulatory issues impacting alternative investments

Below you can view and download comment letters that reflect our industry’s feedback and insights on key legislative and regulatory issues. Browse through the letters to gain a deeper understanding of the issues at hand and the collective viewpoints of IPA’s community.
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IPA Comment Letters 2024
IPA Letter to President-Elect Trump: Support Main Street Investors and Strengthen America’s Capital Markets - (11/22/2024)
IPA Joins Coalition Comment Letter on Draft Annuity Best Interest Regulatory Guidance - (11/8/2024)
IPA Delivers Letter to Republican Leadership on the House Ways and Means Committee Outlining High-Level Tax Policy Priorities for 2025 - (10/15/2024)
IPA Submits Comment Letter to Ohio Securities Division on Registration by Qualification Proposal – (5/3/24)
IPA Supports House and Senate Resolutions of Disapproval under the Congressional Review Act to Invalidate the Final DOL Rule and Related Exemptions (5/15/24)
IPA joins Innovation Coalition Statement for the Record on House Ways and Means Hearing on “Expanding on the Success of the 2017 Tax Relief to Help Hardworking Americans” (4/11/24)
IPA Joins Coalition Supporting Ohio SB 199 – (4/19/24)
IPA Joins Coalition Letter on Like-Kind Exchange Budget Proposal – (4/10/24)
IPA Submits Comment Letter to Department of Labor’s Proposed “Retirement Security Rule: Definition of an Investment Advice Fiduciary” and related prohibited transaction amendments – (1/2/24)
IPA Comment Letters 2023
IPA Submits Comment Letter to FINRA on Proposed Changes to Rule 2210 – (12/15/23)
IPA Submits Comment Letter to NASAA on Proposed Revisions to Broker-Dealer Model Rule – (12/4/23)
IPA and the Joint Trades Coalition Submits Comment Letter to NASAA on Proposed Revisions to Broker-Dealer Model Rule – (12/4/23)
Joint Trades Coalition Submits Comment Letter to Department of Labor Requesting More Time for Meaningful Analysis and Comment – (11/8/23)
IPA Submits Comment Letter to Ohio Securities Division on Registration by Qualification Proposal – (10/31/23)
Joint Trades Coalition Submits Comment Letter to Ohio Securities Division on Registration by Qualification Proposal – (10/31/23)
IPA Submits Comment Letter to the SEC on Conflicts of Interest and Predictive Data Analytics Proposal – (10/10/23)
Joint Coalition Letter to SEC on Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker- Dealers and Investment Advisers – (9/19/23)
Joint Coalition Letter to the SEC on the Negative Impacts of the Safeguarding Proposal on Investors, Market Participants, and the Financial Markets – (9/12/23)
Joint Coalition Letter to SEC on Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers Proposal – (9/11/23)
IPA Submits Comments Letter to Ohio Common Sense Initiative on the Ohio Securities Division Registration by Qualification Proposal - (8/30/23)
Industry Coalition Letter Extension Request on SEC Predictive Data Analytics Proposal – (8/15/23)
IPA Submits Letter to FINRA on Regulatory Notice 23-09 – (8/7/23)
IPA Submits Letter to House Financial Services Committee in Support of H.R. 2627 – (5/24/23)
IPA Submits Letter to House Financial Services Committee on Markup of Legislation – (4/26/23)
IPA Submits Comment Letter to Ohio Securities Division on Proposed Amendments to Rule 1301:6-3-09 Registration by Qualification – (4/12/23)
IPA Submits Supplemental Comment Letter to Ohio Securities Division on Rule 1301:6-3-09 Registration by Qualification – (2/28/23)
Industry Coalition Supplemental Comment Letter to Ohio Securities Division on Rule 1301:6-3-09 Registration by Qualification – (2/28/23)
Industry Coalition Letter to Members of Congress on IRS Proposed Look-Through Rule – (3/1/23)
IPA Submits Comment Letter to IRS on FIRPTA and Proposed Regulations Impacting the Determination of Domestically Controlled REIT Status – (2/27/23)
Industry Coalition Letter to Treasury on FIRPTA and Section 892 Proposed Regulations – (2/27/23)
IPA Submits Comment Letter to Ohio Securities Division on Ohio Division of Securities Rule 1301:6-3-09 Registration by Qualification – (2/3/23)
Industry Coalition Comment Letter to Ohio Securities Division on Ohio Division of Securities Rule 1301:6-3-09 Registration by Qualification – (2/3/23)
IPA Comment Letters 2022
Industry Coalition Comment Letter to DOL on the Independent Contractor Classification Proposal – (12/13/22)
Industry Coalition Letter to IRS to Extend Remote Notarization – (11/30/22)
IPA Submits Comment Letter on NASAA’s Proposed Revisions to the Form U-1 – (10/22/22)
IPA Submits Comment Letter to NASAA on Proposed Revisions to REIT Guidelines – (9/12/22)
Real Estate Industry Coalition Letter to NASAA on Proposed Revisions to REIT Guidelines – (9/12/22)
Financial Services Industry Coalition Letter to NASAA on Proposed Revisions to REIT Guidelines – (9/12/22)
Retirement Industry Coalition Letter to NASAA on Proposed Revisions to REIT Guidelines – (9/12/22)
IPA Submits Comment Letter to SEC on Climate-Risk Disclosure Proposal – (6/17/22)
Industry Coalition Letter to SEC on Climate-Risk Disclosure Proposal – (6/13/22)
IPA/DCALTA Coalition Letter In Support of Retirement Savings Modernization Act – (5/12/22)
IPA Submits Comment Letter to Ohio Securities Division on Revised Rule 1301:6-3-09 – (5/9/22)
IPA Submits Comment Letter to FINRA on Regulatory Notice 22-08 (Complex Products) – (5/9/22)
Industry Coalition Letter to SEC on Extension to Climate-Risk Disclosure Proposal  – (4/14/22)
Industry Coalition Letter to SEC on Length of Comment Periods – (4/5/22)
IPA Submits Comment Letter to SEC on Share Repurchase Disclosure Modernization Proposal – (3/28/22)
Industry Coalition Letter to OMB on DOL NPRM – PTE Procedure Extension – (3/24/22)
Industry Coalition Letter to DOL on DOL NPRM – PTE Procedure Extension – (3/23/22)
Industry Coalition Letter in Support of the “Economic Continuity and Stability Act” (LIBOR) – (2/28/22)
IPA Comment Letters 2021
Industry Coalition Letter in Support H.R. 4616, the “Adjustable Interest Rate (LIBOR) Act” – (12/7/21)
IPA Submits Comment Letter to Rep. Maloney on PRIA Act of 2021 – (10/26/21)
IPA Submits Comment Letter to Chairman Richard Neal on Sec 138312 – (9/15/21)
Industry Coalition Letter to Senate Finance/House Ways & Means on Budget Reconciliation – (9/7/21)
Industry Coalition Letter to Sen. Kennedy on 1031 Budget Amendment – (8/20/21)
IPA Submits Comment Letter to Ohio Rep. Jean Schmidt on Securities Division Letter – (3/29/21)
IPA Submits Comment Letter to Ohio on Securities Division Rule Review – (3/21/21)
IPA Submits Coalition Letter to Senate Finance and House Ways and Means Committee Chair and Ranking Members Supporting Like-Kind Exchanges – (3/16/21)
IPA Submits Coalition Letter to Treasury Secretary Janet Yellen Supporting Like-Kind Exchange – (3/16/21)
EIG OZ Coalition Comment Letter on CRA ANPR – (2/16/21)
IPA Submits Comment Letter to SEC on FINRA Proposed Rule Change Relating to Private Placement Filer Form Under FINRA Rules 5122 and 5123 – (1/27/21)
IPA Letter to Ohio Securities Division on Use of Gross Offering Proceeds to Fund Distributions – (1/19/2021)
IPA Comment Letters 2020
IPA Submits Response to Ohio Securities Bulletin Regarding Issuer Advertising – (8/12/20)
IPA Submits Comment Letter on DOL Fiduciary Proposal – (8/5/20)
IPA Submits Comment Letter on Proposed Updates to Valuation Practices – (7/31/20)
IPA Submits SEC Comment Letter Regarding Updates to Retirement Space – (7/10/20)
IPA Submits Comment on SEC Exempt Offering Rule Proposal – (6/25/20)
IPA Submits Response to Ohio Securities Bulletin Regarding Non-Listed REIT Valuations – (5/22/20)
IPA Submits Letter to DOL Regarding Defined Contribution Plans – (5/21/20)
IPA Joins Coalition Letter Seeking Clarifications for Loan Modifications – (5/15/20)
IPA Joins Coalition Letter Urging Clarification for 1031 Deadlines – (4/20/20)
IPA Joined an Industry Coalition Letter Requesting Clarification Around Qualifications for the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) – (4/16/20)
IPA Submits Letter to Treasury and Federal Reserve on Main Street Lending Program (MSLP) – (4/16/20)
Emergency Relief for Delaware Statutory Trusts Owning Real Property – (4/14/20)
IPA Submits Comment Letter – LKE Delay Letter to Treasure COVID-19 – (3/23/20)
IPA Submits Comment Letter – Urgent Appeal to Congress Emergency Support for Associations and Nonprofits – IPA ASAE – (3/23/20)
IPA Submits Letter to DOL Regarding Defined Contribution Plans – (5/21/20)
IPA Submits Comment Letter – Accredited Investor Definition Proposal – (3/16/20)
Coalition Letter: IPA Submits Letter to NASAA Regarding Concerns Around Regulation Best Interest Implementation Survey – (2/24/20)
IPA Submits Comment Letter on Investment Adviser Advertisements and Payments to Solicitors – (2/11/20)
Proposed Regulations – Fiduciary Conduct Standard Massachusetts Securities Division – (COALITION LETTER) – (1/6/20)
Proposed Regulations – Fiduciary Conduct Standard Massachusetts Securities Division – (COMMENT LETTER) – (1/4/20)
IPA Comment Letters 2019
Sens. Isakson-Menendez Letter to Treasury Secretary Mnuchin on IRS Notice 2007-55 – (12/18/19)
Real Estate Group Letter Requesting Delay in Implementing Partnership Tax Return Forms – (11/22/19)
Final Joint Trades Letter in Opposition to H.R. 1815, “SEC Disclosure Effectiveness Testing Act” – (10/25/19)
Concept Release on Harmonization of Securities Offering Exemptions File No. S7-08-19 – (9/24/2019)
Dan Cullen and Darryl Steinhause Written Testimony to Treasury Department on Second Set of QOZ Regulations – (7/9/19)
Comments on Proposed Regulations Concerning Proposed Regulations Regarding Investing in Qualified Opportunity Funds (REG-120186-18) – (8/14/19)
IPA Letter to MA Securities Bureau – (7/26/19)
Joint Trade Association Letter on MA Fiduciary Proposal – (7/26/19)
IPA and DCALTA – Ongoing Efforts to Diversify Defined Contribution Plan Portfolios – (7/22/19)
IPA Joins EIG Opportunity Zones Coalition Comment Letter on REG-120186-18 – (7/1/19)
IPA Joins Novogradac Opportunity Zones Working Group Comment Letter on REG-120186-18 – (7/1/19)
IPA Comment Letter on REG-120186-18 – (6/28/19)
IPA Letter on Waters Amendment to Defund Regulation Best Interest – (6/26/19)
IPA Comment Letter on New Jersey Fiduciary Proposal – (6/14/19)
IPA Joins Industry Coalition Comments on New Jersey Fiduciary Proposal – (6/14/19)
IPA Comment Letter on Securities Offering Reform for Closed-End Investment Companies – (6/10/19)
2019 Letter from Coalition Requesting Action on Tax Treaties
IPA Comment Letter on BDC Fund of Funds Arrangement – (5/1/19)
IPA Joins Real Estate Coalition in Supporting the Invest In America Act
Maryland Consumers Best Interest Coalition – Senate Letter – (3/13/19)
Maryland Consumers Best Interest Coalition – House Letter – (3/13/19)
IPA Comment Letter on Maryland House Bill 1127 – Financial Consumer Protection Act of 2019 – (3/13/19)
IPA Comment Letter on Maryland Senate Bill 786 – Financial Consumer Protection Act of 2019 – (3/13/19)
Nevada Joint Trades Letter on Fiduciary Standard Proposal – (3/05/19)
IPA Comment Letter on Nevada Fiduciary Standard Proposal – (2/28/2019)
Dan Cullen’s Written Testimony to Treasury Department on Qualified Opportunity Zone Regulations – (02/13/19
IPA Comment Letter to Treasury Department on Proposed Regulations for Qualified Opportunity Zones – (02/08/19)
Guidance Regarding Investing in Qualified Opportunity Funds (REG-115420-18)
IPA Comment Letters 2018
IPA Joins Novogradac Opportunity Zones Working Group Comment Letter on REG-115420-18 (12/27/18)
IPA Joins EIG Opportunity Zones Coalition Comment Letter on REG-115420-18 (12/27/18)
IPA Joins Industry Coalition Against NJ Fiduciary Proposal (12/14/18)
IPA Comment Letter on New Jersey Fiduciary Duty Rule Pre-Proposal (12/14/18)
IPA Joins Coalition in Support of Invest in America Act (H.R. 6726) (11/21/18)
IPA Comment Letter on 199A Regulations (10/1/18)
IPA Comments on SEC’s Regulation Best Interest Proposal (8/7/18)
IPA Support for S.2765 – Fair Investment Opportunities for Professional Experts Act – (6/20/18)
IPA Support for H.R. 6021 – Small Business Audit Correction Act of 2018 – (6/20/2018)
IPA Support for S. 3004 – Small Business Audit Correction Act of 2018 (6/20/2018)
IPA Joins Industry Coalition Encouraging Treasury Department For Fair Treatment Of Cost Basis For 1031 Exchanges (6-8-2018)
IPA Letter of Support for H.R. 5051, the “Public Company Registration Threshold Act” (3-14-18)
IPA Comment Letter to SEC on Standards of Conduct for Investment Advisers and Broker-Dealers (2-15-18)
IPA Comment Letters 2017
IPA Letter of Support to House Ways & Means Committee Chairman Kevin Brady (11-13-17)
IPA Letter of Support to Senate Finance Committee Orrin Hatch (11-13-17)
IPA Participates in Amicus Brief to Supreme Court – South Dakota v. Wayfair (11-03-17)
IPA Statement of Support for Small Business Credit Availability Act (11-03-17)
IPA Comments on H.R. 1585 – Fair Investment Opportunities for Professional Experts Act (10-19-17)
IPA Requests Delay of DOL Fiduciary Rule Until July 1, 2019 (09/15/2017)
IPA Joins Coalition Comments to State of Nevada Regarding Fiduciary Rule (08/25/17)
IPA Comments on IRS Notice 2017-38: Temporary Regulations under Section 752 – Request to Rescind Bottom – Dollar IPA Payment Obligation Regulations (08/07/2017)
IPA Comments to DOL on Extension to Applicability Date of Fiduciary Duty Rule to January 1, 2018 (07/21/2017)
IPA Urges Senator Orinn Hatch to Preserve the 1031 Like-Kind Exchange (7/17/2017)
IPA Joins Like-Kind Exchange Coalition in Comments to Senator Orinn Hatch on Tax Reform (7/17/2017)
IPA Request for Comments Regarding FINRA Rules Impacting Capital Formation (7/14/2017)
Real Estate Coalition Statement on Tax Reform – House Committee on Ways (6/1/2017)
Real Estate Coalition Statement on Tax Reform – Senate Committee on Finance (6/1/2017)
IPA Urges Secretary Acosta to Delay Fiduciary Rule Implementation (4/28/2017)
IPA Comments regarding RIN 1210-AB79 – Fiduciary Rule Examination (4/17/2017)
IPA Submits Proposals to Foster Economic Growth to Senate Banking Committee (4/14/2017)
IPA Comments on FINRA RN 17-06: Proposed Amendments to Rule 2210 – Communications with the Public (3/27/2017)
IPA Requests Delay of Applicability Date of DOL Fiduciary Duty Rule (3/16/2017)