The Financial Technology Association (FTA) submitted a comment letter in response to a
Request for Information and Comments on Broker-Dealer and Investment Adviser Digital
Engagement Practices issued by the U.S. Securities and Exchange Commission.
The letter reads in part:
FTA appreciates the opportunity to respond to this request for comment on a broad range of
topics involving digital engagement practices, the application of emerging technologies, and
growth of digital investment advisers. The breadth of topics raised underscores how technology
has impacted, and, in many instances, enhanced the financial industry. Financial technology is
consistent with the SEC’s tripartite mission of protecting investors, maintaining fair, orderly and
efficient markets, and facilitating capital formation.
In particular, fintech has had a substantial positive impact on financial markets and introduced
new categories of financial services, increased competition and efficiency, lowered investor
costs, and expanded market participation. The growth of fintech has helped to facilitate wealth
creation for millions of Americans over the last decade, and future innovation holds substantial
promise in helping to close the wealth gap in the United States. Allowing fintech to continue
innovating furthers the SEC’s mission, supports economic growth, and long-term wealth
FTA welcomes the Commission’s effort to begin gathering information on digital engagement
practices and emerging technologies through this request. FTA respectfully cautions the
Commission against regulating innovation, rather than conduct, and against penalizing digital
firms relative to traditional firms. Technology-targeted regulation may fail to solve for identifiable
investor harms and will limit or unnecessarily steer further innovation.