POLICY ADVOCACY
The Leading Advocate for Portfolio Diversifying Investments
The IPA is the leading voice on critical legislative and regulatory issues affecting the Portfolio Diversifying Investments (PDI) industry. Our Policy, Regulatory and Legal Affairs Committee coordinates the resources of the IPA and its members to create opportunities for the advancement of IPA objectives via the regulatory and political process. Through policy advocacy, we communicate directly with state and federal lawmakers and industry regulators, educating them about the distinct positive attributes of PDIs. The Policy, Regulatory and Legal Affairs Committee regularly monitors and develops policy action plans.
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MEETINGS ON CAPITOL HILL
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COMMENT LETTERS
ADVOCACY NEWS
UPCOMING EVENTS
2021 CURRENT ISSUES
We support increased access to investment strategies with low correlation to the equity markets: lifecycle real estate investment trusts (Lifecycle REITs), net asset value REITs (NAV REITs), business development companies (BDCs), interval funds and direct participation programs (DPPs). Through advocacy and industry-leading education, the IPA is committed to ensuring that all investors have access to real assets and the opportunity to effectively diversify their investment portfolios
Below are the IPA’s 2021 policy priorities:
Direct Advocacy, Research/Data, Coalition Building, Grassroots Advocacy, Communications
INDUSTRY GUIDELINES
Bringing Industry Together on Best Practice Guidelines
The IPA is committed to providing Best Practice Guidelines on significant industry issues. Best Practice Guidelines are a set of voluntary best practices designed to advance the Portfolio Diversifying Investments (PDI) industry.
A guideline development process has been established to ensure that IPA members, experts, interested industry participants and relevant agencies inform the deliberative process and have input in the final content of each guideline. During the Guideline Development Process, IPA members will have an opportunity to provide input and comments during the development stages. The Advisor team of each guideline will receive comments and respond accordingly.
COMMENT LETTERS
ACTIVE VOICE ON CRITICAL LEGISLATIVE AND REGULATORY ISSUES
The IPA is the leading voice on critical legislative and regulatory issues affecting the Portfolio Diversifying Investments (PDI) industry. Our Policy and Government Affairs Committee coordinates the resources of the IPA and its members to create opportunities for the advancement of IPA objectives via the regulatory and political process.
Through policy advocacy, we communicate directly with state and federal lawmakers and industry regulators, educating them about the distinct positive attributes of PDIs. The IPA Policy and Government Affairs Committee regularly monitors and develops political action plans.
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)
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 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)
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)
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)
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)
2016
- IPA Requests Delay of Applicability Date of DOL Fiduciary Duty Rule (3/16/2017)
- IPA Request to Trump Administration to Delay Implementation of DOL Fiduciary Duty Rule (11/15/2016)
- NASAA Proposed Amendments to Statement of Policy Regarding REIT Guidelines (09/12/16)
- IPA Supports 1031 Exchanges – A Letter to the Trump Campaign (09/16/16)
- IPA Supports 1031 Exchanges – A Letter to the Clinton Campaign (9/9/2016)
- SEC Review on Accredited Investor Definition (09/6/2016)
- Modernization of SEC Regulation S-K (07/21/16)
- NASAA Electronic Documents and Electronic Signatures (06/01/16)
- Simplification of Disclosure Requirements for Emerging Growth Companies (03/29/16)