Supplemental Comments on Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA provides comments to the Municipal Securities Rulemaking Board (MSRB) on Supervision of Municipal Advisory Activities (Draft Rule G-44), Books and Records (Draft Rule G-8), and Preservation of Records (Draft Rule G-9).
SIFMA supports the MSRB’s efforts to ensure that municipal advisors are properly supervised and that all municipal advisors adopt a supervisory structure for municipal activities not already subject to supervision under Rule G-27. As discussed in SIFMA’s comment letters submitted previously to the MSRB in response to other proposed MSRB rule changes, since the Securities and Exchange Commission (SEC) has not yet adopted final rules that would define the scope of activities that trigger municipal advisor registration, and therefore the universe of potential registrants, the Proposal to establish a supervisory system for such activity is premature and may be an inefficient use of resources. Accordingly, SIFMA requests an opportunity to provide further comments once the SEC has completed its rulemaking defining the scope of activities subject to municipal advisor registration – and supervision. Once the SEC has completed its rulemaking defining the scope of personnel and activities subject to municipal advisor registration, we would expect the MSRB to propose a supervisory regime for non-dealer municipal advisors of similar robustness as the requirements of G-27 which covers dealer advisors.
SIFMA states the MSRB should delay its rulemaking until the SEC determines the definition of “municipal advisor.”
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
SIFMA and SIFMA AMG provided comments to the Commodity Futures Trading Commission (CFTC) on their request for public comment on…
SIFMA AMG provided comments to the Federal Deposit Insurance Corporation (FDIC) on their consideration of various proposals to revise the…
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