Access to Americans’ Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern
SIFMA provided comments to the U.S. Department of Justice, National Security Division on the proposed rulemaking concerning bulk data transfers…
Summary
SIFMA’s Asset Management Group (AMG) provides additional comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury on final regulations for the Report on of Foreign Bank and Financial Accounts (FBAR). SIFMA AMG requests that:
- Employees of AMG member firms and its subsidiaries, affiliates, service providers, and agents are exempted from the requirement to file individual FBAR reports relating to any authority that they have to instruct foreign banks and custodians on behalf of clients and FinCEN should allow AMG member firms to submit a consolidated form.
- Modifications are made to reporting responsibilities of former employees.
- Privacy requirements in investment contracts are respected.
- FinCEN provides greater clarity on filing requirements.
More Submissions
Type:
Proposed Rule Change, as Modified by Partial Amendment No. 1, to Modify the GSD Rules to Facilitate Access to Clearance and Settlement Services of All Eligible Secondary Market Transactions in U.S. Treasury Securities (Joint Trades)
SIFMA, SIFMA AMG, the Investment Company Institute (ICI), Alternative Investment Management Association (AIMA), and the International Swaps and Derivatives Association…
Type:
Proposed Rule Change to Modify the GSD Rules (I) Regarding the Separate Calculation, Collection and Holding of Margin for Proprietary Transactions and That for Indirect Participant Transactions, and (ii) To Address the Conditions of Note H to Rule 15c3-3a (Joint Trades)
SIFMA, SIFMA AMG, the Investment Company Institute (ICI), Alternative Investment Management Association (AIMA), and the International Swaps and Derivatives Association…