2004 Comment Letters

 

12/31/04
SIA Response To The United States Trade Representative's Federal Register Notices Of August 17 And November 9, Soliciting Comments About Ways To Further Strengthen The Transatlantic Economic Relationship
12/16/04
Request for Extension re Proposed Rule on Fair Administration and Governance of Self-Regulatory Organizations
12/15/04
Joint Letter To Congressman Jim Sensenbrenner Expresses Strong Support In Clarifying Physical Presence Is The Appropriate Constitutional Nexus Standard For State Assessment Of Business Activity Taxes, Specifically The BAT Act
12/13/04
SIA Comments To The SEC On Proposed Rule Change By The NYSE Relating To The Exchange's Direct+ Trading Facility
12/03/04
SIA Requests Guidance Of The Treasury On Issues Arising Under New Internal Revenue Code Section 965, Which Provides A Temporary Dividends Received Deduction To Certain U.S. Corporations Receiving Cash Dividends From Controlled Foreign Corporations (CFCs)
11/23/04
Separate Bidder Comment Letter to Treasury
11/22/04
SIA Comments to the SEC on NYSE Proposed Rule Changes Regarding Non-Managed Fee-Based Account Programs
11/15/04
SLGS Regulations Should Maintain Flexibility for Issuers, Address Treasury Concerns
11/10/04
Comments To The SEC On STP Issues, Re: SEC Concept Release: Securities Transactions Settlement
11/06/04
Response to IOSCO Proposed Code of Conduct for Credit Rating Agencies
10/29/04
Comment on FASB ‘Other-Than-Temporary Impairment’ Interpretation
10/27/04
SIA Petitions The NASD To Establish A Uniform Methodology For Calculation Of Section 31 Fees
10/27/04
The State Regulation And Legislation Committee Of The SIA Comments On The Division's Proposed Revisions To The Uniform Securities Act (2002) And The Accompanying Proposed Rules
10/27/04
SIA Submits To The SEC Replacement Language For The Terms "Section 31 Fee" Or "SEC Fee" Currently Used On Customer Confirmations
10/22/04
SIA Comment Letter on Real Time OpenBook Proposal
10/22/04
Comments To William F. Sweetnam, Jr., Office of Tax Policy Regarding Non-Qualified Deferred Compensation, SIA And Its Member Companies Identify Four Issues That Require Prompt Guidance From The Treasury
10/20/04
SIA Comment Letter to IOSCO re Principles on Outsourcing of Financial Services for Market Intermediaries
10/20/04
SIA Comments To The SEC On The Commission's Notice Of Proposed Rulemaking Under The FACT Act With Regards To Disposal Of Consumer Report Information
10/15/04
Association/ISDA Response to Basel/IOSCO Group's Trading Book Survey
10/12/04
Comments of the SIA's Technology Management Committee Regarding the Draft Report of the Best Practices and Metrics Team of the Corporate Information Security Working Group
10/01/04
SIA Comments To The SEC Regarding NYSE Hybrid Market Proposal
09/23/04
SIA Comments On Two Proposals By The Fincen Regarding Imposition Of Special Measures Against Infobank And First Merchant Bank OSH Ltd. As Primary Money Laundering Concerns
09/22/04
Joint Comment Letter From TBMA And The SIA To The Washington Utilities And Transportation Commission Regarding Rulemaking To Consider Financial Reporting Rules
09/22/04
SIA Comments on Broker Dealers Deemed Not to be Investment Advisers
09/17/04
SIA Comments to the SEC Regarding Proposed NASD Rule Change Relating to Disclosure of Fees and Expenses in Mutual Fund Performance Sales Material
09/15/04
Comment Letter Filed with FSA on Research Disclosure
09/15/04
SIA Letter To The MRSB Responds To Notice 2004-16, Seeking Comments On Modifications To The Rules Governing Advertisements And Disclosures Relating To College Savings Plans ("529 Plans")
09/13/04
SIA Comments To The FTC Regarding The Definitions, Implementation, And Reporting Requirements Under The CAN-SPAM Act
09/13/04
SIA Comments To California State Capitol In Strong Support Of A Veto For AB 1829, Legislation Mandates State Agencies And Local Governments Can Only Enter Into Service Contracts Where All Contract Work Will Be Performed By Workers Located Within The U.S.
09/03/04
Association and AMF Comment on FASB 'Other-Than-Temporary Impairment' Rule
09/02/04
Comment Letter re Proposed Statement of Financial Accounting Standards, Fair Value Measurements
09/01/04
Comment Letter to Treasury on Pre-release of CUSIPs
09/01/04
SIA Comments To The SEC On The Proposed Regulation B Under Section 3(A)(4) Of The Securities And Exchange Act Of 1934
08/24/04
SIA Comments To The SEC In Response To Amendment To Proposed Chief Executive Officer Certification Requirement, Which Propose New NASD Rule 3013 and Accompanying Interpretative Material
08/19/04
Comment Letter on Amendments to MSRB Rule G-34
08/18/04
Supplement To SIA's Comments To The SEC On The Proposed Regulation S-AM
08/17/04
SIA Comments to NASD RE: Proposed Amendments to NASD Rule 2320(a), NASD's Best Execution Rule; Amendment No. 1
08/13/04
Implementation of Affiliate Marketing Provisions of Section 214 of the Fair & Accurate Credit Transactions Act of 2003
08/12/04
SIA Letter To The Treasury Regarding Foreign Issuer Certification Procedures With Respect To Foreign Dividends
08/12/04
SIA Comments To The IRS Regarding Foreign Issuer Certification With Respect To Foreign Dividends
08/10/04
SIA Comments To The SEC In Response To The Rule Proposal Regarding Ownership Reports And Trading By Officers, Directors, And Principal Holders
08/09/04
SIA Comments To The NASD On The Notice To Members Which Seeks Input Regarding Proposed New Rules Governing Deferred Variable Annuity Sales Practices And Supervisory Procedures
08/04/04
SIA Response Letter To The IRS Regarding Two-Part Rule That Would Permit Taxpayers To Trace Proceeds Of Borrowings To Specific Taxable Investments, And The Tracing/Allocation Approach
08/03/04
SIA Comments On The Draft ESCB-CESR Standards For Securities Clearing And Settlement Systems In The European Union Of May 2004
07/29/04
Comment Letter to CESR on Pre-Trade Transparency Provisions of MIFID
07/28/04
SIA Operations Committee Comments On The SEC Proposed Rule 17Ad-20 Under The Exchange Act; Re Issuer Restrictions Or Prohibitions On Ownership By Securities Intermediaries
07/23/04
Comment Letter Commends NASD for Increased Transparency
07/20/04
Comment Letter on Real-Time Trade Reporting Filed with SEC
07/19/04
Joint Comment Letter on Interagency Statement on Complex SF Transactions
07/19/04
The BMA, The ISDA And The SIA Comment On The Proposed Interagency Statement On Sound Practices Regarding Complex Structured Finance Activities
07/12/04
SEC's Proposed Rules for ABS - Comment Letter
06/30/04
The BMA and SIA Comment on the Exposure Draft of the SAode of Standard Practices for Participants in the Credit Rating Process Released by the Association for Financial Professionals, the Association of Corporate Treasurers, and the Association Francaise
06/30/04
SIA Comments On The SEC's Proposed Regulation NMS Under The Exchange Act
06/24/04
SIA's Comment On The Petition For Rulemaking Regarding Shareholder Communications, Submitted On Behalf Of The Business Roundtable (BRT) On April 12, 2004
06/17/04
Comment Letter on Imposition of Special Measure Against Commercial Bank of Syria as Primary Money Laundering Concern
06/16/04
Best Practices For Automating Clearances and Settlements
06/16/04
SIA Comment Letter Regarding SEC Concept Release on Securities Transaction Settlement
06/11/04
Comment Letter on BOE's Sterling Money Market Reform Proposal
06/08/04
SIA Letter To Congressman Bill Thomas Supporting H.R. 4520, The American Jobs Creation Act Scheduled For Mark-Up In The Committee On Ways And Means On Thursday, June 10, 2004
06/07/04
Association, ISDA, LIBA File Comment Letter on Basel Accord
06/04/04
Alternative to MSRB's Proposed Amendments to Rule G-38
06/04/04
Join Letter To Congretssman Bill Thomas Opposing The Section 911 Change In The Senate FSC Bill
06/04/04
Comment Letter to SEC Regarding Rule Proposal Modfying SRO Rulemaking Process
05/28/04
Comment Letter on the Basel/IOSCO Draft Trading Book Survey
05/25/04
Comment Letter on Side-By-Side Management of Hedge Funds
05/13/04
Tax Parity Letter Supporting Favorable Tax Treatment to all Qualified 529 Plans
05/10/04
Proposal to Apply Mandatory Redemption Fees for Redeemable Fund Securities
05/10/04
Proposal to Prohibit the Use of Brokerage Commissions to Finance Distribution
05/05/04
SIA Comments To The Department Of Labor Regarding Proposed Improvements Under Consideration By EBSA To The EFAST Filing System For Annual Submission Of Form 5500 And Form 5500-EZ
05/04/04
SIA Letter In Support Of Rhode Island¿s H. 7615, Legislation That Extends Favorable State Tax Treatment To All Qualified 529 Plans
04/22/04
Letter to US Senate Supporting S. 1637, the Jumpstart Our Business Strength Act (JOBS)
04/20/04
SIA Letter To The FTC Regarding Notice Of Proposed CAN-SPAM Act Rulemaking
04/16/04
Response to Proposed PSR Policy Change
04/16/04
SIA Comments On The SEC Concept Release Regarding Competitive Developments In The Options Markets
04/12/04
SIA Comments To The SEC Regarding Confirmation Requirements And Point Of Sale Disclosure Requirements For Transactions In Certain Mutual Funds And Other Securities With Attached Appendix, SEC/SIA Estimate Of Costs
04/05/04
SIA Comments To The SEC Opposing The Proposed Fee Increases For Options Market Data
04/01/04
SIA Savings And Retirement Committee Comments On Proposed Automatic Rollover Regulation
03/30/04
SIA Comments To The SEC Regarding The NASD Proposed Rule Change Related To The Entry Of Locking Or Crossing Bids Or Offers By ECNs Participating In Nasdaq's Supermontage System
03/29/04
SIA Comments To The SEC On The Interagency Proposal To Consider Alternative Forms Of Privacy Notices Under The Gramm-Leach-Bliley Act
03/24/04
SIA Letter To Congressman Oxley Regarding State-Sponsored 529 Tuition Savings Plans
03/22/04
SIA Comments In Support Of Proposed Rules By The OCC Relating To CMTA
03/15/04
SIA Comments To The SEC On Proposed Investment Adviser Codes Of Ethics
03/05/04
SIA Comments To The SEC On The Proposed Rule Regarding Collection Practices Under Section 31 Of The Securities Exchange Act
03/02/04
Weather-Related Derivatives Contracts are Capital Market Products
02/27/04
SIA Comments To The SEC On Proposed Rule On Alternative Net Capital Requirements For Broker-Dealers That Are Part Of Consolidated Supervised Entities
02/25/04
SIA Letter To House Financial Services Committee In Support Of H.R. 2179, The Securities Fraud Deterrence And Investor Restitution Act
02/20/04
Comments On SEC Concept Release And Response To Request For Comments On Measures To Improve Disclosure Of Mutual Fund Transaction Costs
02/19/04
SIA Comments To SEC On Proposed Regulation SHO; Specifically, On The Need For A Hedging Exemption For Short Sales
02/17/04
TBMA Files Comment Letter on NASD's Proposed Expansion of Trading Activity Fee to Certain Fixed Income Securities
02/17/04
SIA Comments To The Treasury Seeking Clarification Of Term "Investment Bank" For Purposes Of U.S.-Japan Income Tax Treaty
02/13/04
SIA Comments To The SEC Regarding Disclosure Of Breakpoint Discounts By Mutual Funds
02/06/04
SEC Late Trading Proposal - Amendments To Rules Governing Pricing of Mutual Fund Shares (Release No. IC-26288; File No. S7-27-03)
02/06/04
Joint Letter To The SEC Regarding Amendments To Rules Governing Pricing Of Mutual Funds
02/06/04
The SIA and The BMA Comment To The SEC on Proposed CCO and CEO Certification Requirement
02/06/04
Proposed Mutual Funds Disclosures Regarding Market Timing and Selective Disclosure of Portfolio Holdings (File No. S7-26-03)
01/30/04
SIA Comments To The SEC In Regards To Proposed Regulation SHO; Modernizing The Regulation Of Short Sales, And Addressing Certain Abusive Short Selling Practices And General Fails/Locate Requirements
01/28/04
SIA Letter To Congress In Support Of Adding H.R. 975, The Consumer Bankruptcy Bill, To S. 1920, The Agricultural Bankruptcy Bill
01/26/04
Joint Industry Letter To Commodity Futures Trading Commission Chairman In Regards To The Designation of U.S. Futures Exchange As A Contract Market
01/23/04
SIA Comments Regarding NASD Notice To Members 03-72; Proposed Rule Governing Allocations And Distributions Of Shares In IPOs
01/22/04
SIA Comments To The NASD On The Proposal Regarding Disclosure Of Mutual Fund Expense Ratios And Sales Charges In Performance Advertising
01/20/04
SIA Comments To the SEC Regarding The Proposed Establishment Of An SEC Office Of Global Security Risk
01/20/04
SIA Comments To The SEC Relating To Expungement Of Customer Dispute Information NASD's CRD
01/12/04
SIA Comments With Cover Letter To The IRS Regarding Proposed Regulations Addressing The Treatment Of Services Under Section 482 And The Allocation Of Income And Deductions From Intangibles
01/09/04
Response to FSA Consultation Paper 205
01/09/04
SIA Comments To The SEC Regarding NASD Proposed Amendments To Branch Office Definition
01/06/04
SIA Comments To The SEC For No Action Relief With Regards To The Patriot Act CIP Rule

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