Date: September 6, 2016 Issue: Systemic Risk and Capital Standards To: Brent J. Fields, Secretary  Filing Type: Regulatory Description: The CCMC agrees with the spirit of the Proposed Rule, but we have strong concerns relating to its extension of liability through Section 206(4)’s anti-fraud provisions. We also believe that business continuity plans should remain confidential and … Continue reading Letter to the SEC on Adviser Business Continuity and Transition Plans (09/6/16)