SIFMA provides comments to the Securities and Exchange Commission (SEC) on SEC Rule 15c3-5 under the Securities Exchange Act of 1934 (Act) regarding risk management controls for brokers or dealers with market access.  SIFMA requests that the SEC revise the effective date of Rule 15c3-5 under the Act to provide for a phased implementation of the Rule, as it has for other rules with similar system implications. Rule 15c3-5 will require broker-dealers that access or provide access to trade directly on an exchange or an alternative trading system (ATS) to implement risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of this business activity.