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As demonstrated by a Boston Consulting Group (“BCG”) report, the costs of user fees would be significantly less than the costs of SRO oversight. Further, if an investment adviser SRO were mandated, the resulting new oversight responsibilities would require the SEC to expend significant additional resources. In summary, the IAA strongly believes that there are better answers than the option presented by H.R. 4624. Now that the bill has been defeated, the IAA strongly urges Congress to consider other—and better—options.



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