MFA, et al. v. SEC
Court: U.S. Court of Appeals (Fifth Circuit) Amicus Issue: Whether the SEC’s securities lending and short reporting rules are arbitrary…
SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Municipal Securities Rulemaking Board’s (MSRB’s) notice of filing of a proposed rule change consisting of amendments to Rule G-16 on periodic compliance examination and Rule G-9 on preservation of records, SR-MSRB-2011-19. While SIFMA supports the proposed amendments to Rule G-16, which would allow FINRA and the MSRB to establish a risk-based compliance program consistent with FINRA’s requirement for cycle examinations of all other FINRA members, SIFMA does not support the proposed amendments to Rule G-9, which would extend certain record keeping requirements from three years to four years. SIFMA believes that such a change is not warranted to support the proposed changes to the frequency of the cycle examinations.