It’s time for the Securities and Exchange Commission to take a step back and “holistically consider the practical ramifications” of more than a dozen new rules and proposals it has issued since SEC Chairman Gary Gensler was sworn in, said attorneys for the Investment Adviser Association in a letter to the agency late Monday.

“Taken together, these regulations will significantly overhaul the current regulatory regime for advisors,” which the agency hasn’t demonstrated is broken, said Gail Bernstein, the IAA’s general counsel.

The proposed rules will also “disrupt existing infrastructures and relationships, with substantial implications—foreseen and unforeseen—for advisors, investors, service providers and the markets,” she continued.

Before adopting any new rules, the IAA wants the SEC to “explicitly and cohesively” address the implications of its new proposals for RIAs when it comes to outsourcing, cybersecurity and procedures for protecting customer records and safeguarding assets.

These new proposals include “duplicative and potentially inconsistent requirements,” Bernstein said. She pointed out issues of particular concern when it comes to cybersecurity and Regulation S-P, which requires firms to adopt written policy procedures for protecting customer records. These new proposals require RIAs to negotiate new vendor contracts, often with the same parties, but with different requirements and different implementation time lines.

Bernstein said in an interview that, pragmatically, individual firms and even the industry at large are unlikely to be able to renegotiate legal contracts with large vendors such as Amazon’s cloud services, for instance, which the SEC is attempting to mandate.

The association is also asking the SEC to:

• Undertake “a more expansive, accurate, and quantifiable assessment of the cumulative costs, burdens, and economic effects” that all pending advisor proposals would impose on advisors, clients and other market participants;

• Directly speak to the ways the proposals would affect smaller advisors and “provide explicit alternatives”;

• Seek public feedback before taking final action on any of the proposals and get “a comprehensive implementation time line for tiered and staggered compliance requirements and dates for all these proposals.”

“We think it’s incredibly important for us to engage with the SEC and help them understand how all of this will play out on the ground, Bernstein told Financial Advisor magazine.

“While they are very open to meeting with us, they have to do economic analysis to show the impact of each rule on small advisors and provide alternatives,” argued Bernstein, who said 91% of the RIA industry has 100 or fewer staff members and should be considered small businesses for this purpose.

“I think what we’re seeing is that while the agency tries to do economic analysis, they simply don’t have the data,” Bernstein added.

Jeff Brown, the senior vice president of legislative and regulatory affairs at Charles Schwab & Co., also voiced concern at the IAA’s Adviser Advocacy Day in Washington, D.C., held June 7 and 8, over what he called the “poor cost-benefit analysis” that he said runs through all the latest SEC proposals.

“It’s almost as if the SEC has decided that they don’t care about the quality of the proposals they produce. Everywhere you look they admit that they don’t really know what’s going on, but they have assumptions. They always minimize costs and maximize benefits. Often you look at the proposals and wonder, ‘What is the benefit of this?’” Brown said.

“In the end, we don’t know how all these rules will work together. There is no discussion of that or contemplation that they may work together or against each other. A lot of this could end up being decided by the courts, but that could be years from now. You have to start spending money now to comply because you don’t know what the courts will do years from now,” he said.

He called the potential for litigation a calculated risk the SEC readily accepts. “At some point, the SEC figures the industry will end up spending so much money getting ready to comply that they won’t want litigation to go forward. It’s a calculated maneuver,” Brown added.

An SEC spokesperson responded, “The SEC benefits from robust engagement from the public and will review all comments submitted during the open comment period. Generally, we respond to comments received as part of the final rulemaking and not beforehand.”