The Securities and Exchange Commission’s (SEC) potential reevaluation of the assets under management (AUM) threshold that distinguishes state-registered investment advisers from their federally registered counterparts warrants monitoring. Acting SEC chairman Mark Uyeda’s recent statements at a joint conference with the North American Securities Administrators Association (NASAA) have sparked important discussions within the RIA community.

The Dodd-Frank Act of 2010 significantly altered the regulatory landscape, setting the current AUM threshold for state registration at $100 million. This framework aimed to streamline oversight, allowing the SEC to focus on larger, more complex advisory firms, while state regulators concentrated on smaller entities.

However, Uyeda makes a valid point: the substantial growth in the number of advisers, particularly those managing between $100 million and $1 billion in AUM since the 2012 Dodd-Frank compliance date, suggests this equi