2005 COMMENT LETTERS

12/19/05
SIA's Tech & Reg Committee Letter Re: new NASDAQ Services Agreement and other exchange membership application materials sent by NASDAQ to SIA members
12/13/05
Comments on TRACE Reporting of Transactions Connected with Options, Swaps
12/14/05
Regulation SHO Working Group filed a letter with the Securities and Exchange Commission (SEC) regarding a proposed rule change filing by the NASD
12/14/05
Joint Letter To The Speaker Of The House Explains Concerns With Title II of H.R. 4473, "The CFTC Reauthorization Act"
12/07/05
SIA Comment Letter Regarding Request for Expedited Guidance Concerning the Withholding, Reporting and Deposit Procedures with Respect to Section 302 Distributions
12/07/05
SIA Comment Letter Regarding Request for Expedited Guidance Concerning the Withholding, Reporting and Deposit Procedures with Respect to Section 302 Distributions
12/07/05
Joint Letter to U.S. House of Representatives Regarding the House Agriculture Committee's Draft Bill to Reauthorize the Commodity Futures Trading Commission (CFTC)
12/07/05
Joint Letter to U.S. House of Representatives Supporting Extension of a Terrorism Insurance Program Before Congress
12/07/05
Comment Letter Regarding The Depository Trust Company Notice of Filing of Proposed Rule Change Relating to Compliance with Regulations Administered by the Office of Foreign Assets Control
12/02/05
Comment Letter Regarding NASD Request to Extend OATS Reporting Requirement to OTC Equity Securities
12/01/05
SIA Letter Regarding Proposed New York Stock Exchange Rule 340 ("Outsourcing: Due Diligence and Conditions Required in the Use of Service Providers") and proposed amendment to Rule 342.30(c) ("Annual Report and Certification")
12/01/05
SIA Letter Regarding Proposed Commission Guidance Regarding Client Commission Practices Under Section 28(e) of the Securities Exchange Act of 1934 (Release No. 34-52635, File No. S7-09-05)
11/30/05
SIA Letter to Speaker Hastert Encouraging the Leadership to Schedule H.R. 2830 for a Floor Vote in December 2005
11/30/05
Joint comment letter responding to the proposed FASB Staff Position on FIN 46(R) regarding the determination of variability to be considered in applying FIN 46(R)
11/29/05
NASD Urged to Make Historical TRACE Information Publicly Available for Study
11/21/05
Joint Letter Responding to FASB Working Draft of Statement of Financial Accounting Standards No. 15X, Fair Value Measurements and the Proposed FASB Staff Position
11/21/05
Capital Steering Committee Comments Re: Alternative Market Risk and Credit Risk Capital Charges for Futures Commission Merchants and Specified Foreign Currency Forward and Inventory Capital Charges
11/16/05
Comment Letter on Proposed Amendment to Best Execution Rule
11/08/05
Operations Committee of the SIA comments on NASD Notice To Members 05-61, in which the NASD solicits comment on a possible realignment of the Trading Activity Fee (TAF)
11/02/05
Letter to Chairman Bond and Chairman Knollenberg in Regards to Establishment of a U.S. Treasury Financial Attache in Key Financial Markets, with attachment
11/02/05
FSCC Letter to Chairman Stearns and Ranking Member Schakowsky Regarding the "Data Accountability and Trust Act" to be considered on November 3
10/26/05
TBMA Recommendation on 30-Year Bond Issuance
10/26/05
FSCC Letter to Senators Specter and Leahy Regarding the Markup on "Personal Data Privacy And Security Act Of 2005" Which Will Be Considered By The Judiciary Committee October 27, 2005 Expresses Continued Concern
10/19/05
Joint Letter to Senators Specter and Leahy Voices Concerns with Several Aspects of the "Personal Data Privacy and Security Act of 2005" (S. 1789)
10/17/05
Comments to Treasury on Hurricane Katrina Rebuilding
10/13/05
SIA BMA Letter to SEC Re Auditors Due Diligence - Positions Taken by the AICPA at Oct. 11 Meeting Confirm That White Paper II Must be Publicly Repudiated
10/06/05
SIA-TBMA Letter on AICPA Draft White Paper
10/06/05
SIA/BMA Letter to American Institute of Certified Public Accountants Strongly Opposes Proposals Contained In Draft White Paper That Would End Auditor Participation In The So-Called "Due Diligence" Process, Jeopardizing Investor Protection
10/04/05
Letter Supporting Cross-Trading in Pension Bill
09/26/05
The SIA Trading Committee Letter to the SEC Re: Possible Exemptions from Reg NMS for Certain ETFs and ATSs
09/19/05
The SIA Submits Comments To The SEC Regarding NASD Rule 2821 Governing Deferred Variable Annuity Sales Practices And Supervisory Procedures
09/14/05
The Self Reg. and Supervisory Practices Committee of the SIA Comments Regarding Proposed Changes to Exchange Rule 342 Requiring CEO Certification
09/12/05
SIA Provides List For The SEC's Consideration Of Additional Regulatory Relief That SIA Member Firms Believe To Be Necessary Due To The Damage Caused By Hurricane Katrina
09/07/05
Letter on Recycling for FFEL Program Loans
09/07/05
Amendment No. 3 Comment Letter Filed: NASD Rule 2320(a) Governing 'Best Execution'
08/24/05
SIA Comments to the SEC Regarding Rule Change Relating to Amendments to NASD Rule 3370
08/17/05
SIA's Committee On The Federal Taxation Of The Securities Industry Appreciates The Opportunity To Comment To The IRS Regarding Proposed Regulations Establishing Book/Tax Conformity Safe Harbor Under Section 475
08/15/05
TBMA Files Comment Letter Relating to NYSE's Request for Exemption from Section 12(a) for Certain Debt Securities
08/12/05
Clearing Firms Committee of the SIA Comments on Proposed Amendments to NASD Rules 3150 and 3230 Governing the Reporting of Data to Clearing Firms by Correspondent Firms
08/05/05
The Self-Reg. and Supervisory Practices Committee of the SIA Comments to the NASD Regarding Non-Cash Compensation Rules
08/04/05
SIA Comments Re: the issue of research analyst objectivity and NASD Rule 2711 and NYSE Rule 472, as well as the SEC Regulation AC
08/02/05
Comments to the SEC Re: Proposed Rule Changes to NASD Code of Arbitration Relating to Written Explanations in Arbitration Awards
07/29/05
SIA Letter to MSRB Re: Notice 2005-28 - Request for Comments on Draft Interpretation on Customer Protection Obligations Relating to the Marketing of 529 College Savings Plans
07/27/05
SIA Comments to SEC Re: Notice of Proposed Rule Changes Relating to Amendments to NASD Rule 3011 and the Adoption of Related Interpretive Material and Amendments to NYSE Rule 445
07/27/05
SIA Comment Letter to SEC Regarding NASD Proposed Amendments Relating to the Release of Information Through the Public Disclosure Program
07/26/05
TBMA/AMF Send Letter on Senate Pension Bill
07/26/05
SIA Comments to FinCen Re: Proposed Revisions to Suspicious Activity Report by the Securities and Futures Industries (SAR-SF)
07/26/05
SIA Comments on the NASD Rule proposal regarding amendments to the Order Audit Trail System (OATS)
07/22/05
Comment Letter on Resumption of 30-Year Treasury Bonds
07/22/05
Market Data Subcommittee of The Tech. And Reg. Committee of The SIA Comment on Proposed Rule Change Re: Display/Dissemination Requirements for NYSE Openbook
07/20/05
Industry Groups Oppose CEA Legislation
07/20/05
Joint Association Letter to Senator Chambliss Registering Opposition To Legislation Reauthorizing The Commodity Futures Trading Commission (CFTC)
07/20/05
Letter to SEC Regarding Proposed Amendment No. 5 to a Rule Change by the NYSE Relating to Enhancements to the Exchange's Existing Automatic Execution Facility Pilot (NYSE Direct +)
07/20/05
Industry Letter to Senators Chambliss and Tom Harkin Regarding CFTC Reauthorization Bill
07/19/05
Letter on Student Loan Recycling
07/18/05
Letter to Senator Christopher S. Bond Regarding Establishment of a U.S. Treasury Financial Attache in Key Financial Markets
07/18/05
SIA's Market Data Subcommittee Of The Technology And Reg. Committee Is Pleased To Comment On Proposed Rule Change Regarding Enterprise License Fee For Totalview
07/15/05
SIA Letter to IOSCO RE: Public comment on Compliance Function at Market Intermediaries
07/14/05
SIA Letter to the Department of Labor Regarding OLMS Question and Answer Guidance of June 22, 2005
07/13/05
Letter to IRS Regarding Record Retention And Production Requirements In Proposed Regulations Establishing Book/Tax Conformity Safe Harbor Under Section 475
07/13/05
Arbitration and Litigation Committee of the SIA Offers Comments to the SEC about the Proposed NASD Code of Arbitration Procedure for Customer Disputes
06/28/05
Senior Executives Group Supports Changes to Pension Protection Act
06/28/05
SEG Files SEC Comment Letter on NASD Mark-up Policy
06/28/05
Comment Letter on NASD Mark-Up Policy
06/27/05
The SIA Comments To The FTC Regarding Notice Of Proposed Rulemaking Under The CAN-SPAM Act, Project No. R411008
06/23/05
SIA/BMA Letter To Chairman Shelby To Express Support For A Terrorism Insurance Program
06/17/05
Comment Letter on Circular 230
06/17/05
SIA Comments To The IRS Re: Proposed Regulations Under Section 403(B) Of The Internal Revenue Code
06/09/05
TBMA and SIA File Joint Comment Letter to Suggest Changes to Definition of NRSRO
06/09/05
BMA/SIA Comment Letter to the SEC on Definition of Nationally Recognized Statistical Rating Organizations; File No. S7-04-05
05/31/05
SIA Comments To The FSA On Consultation Paper 05/5 Which Sets Out Draft Rules Designed To Implement Policy Decisions Published In Policy Statements 04/13 And 04/23 On Bundled Brokerage And Soft Commission Arrangements
05/27/05
SIA Ad Hoc Committee Comment Letter on the Recent Basel II Consultative Document -- The Application of Basel II to Trading Activities and the Treatment of Double Default Effects
05/27/05
SIA Ad Hoc Committee Comment Letter on the Recent Basel II Consultative Document -- The Application of Basel II to Trading Activities and the Treatment of Double Default Effects
05/27/05
Cross Product Netting Comment Letter to Basel Committee/IOSCO
05/27/05
SIA Comments Regarding NASD Notice to Members 05-25, Pre-Use Filing of Advertisements and Sales Literature for New Types of Securities and of Television, Video and Radio Advertisements
05/25/05
SIA Comments on the Two Separate Proposals Issued by the Financial Crimes Enforcement Network Regarding Imposition of Special Measures Against Multibanka and VEF Banka as Primary Money Laundering Concerns
05/11/05
SIA Comments To The SEC On Proposal By The NYSE And Relating To Efforts Of The NYSE And The NASD To Harmonize Similar Rules Regarding Research Analysts And Separate Comments On Chairman Donaldson's Remarks On Issuer Retaliation
05/09/05
Comment Letter Regarding Mutual Fund Redemption Fee Release No. IC-26782, File No. S7-11-04
05/05/05
TBMA Files Comment Letter to SEC on MSRB Rule G-38
05/04/05
Comments to the SEC Regarding NASD Disclosure and Consent Requirements When Trading on a Net Basis with a Customer
04/29/05
Request for Guidance Concerning Implementation of The Substantial Reduction in The U.S. Withholding Tax Imposed on Certain Dividends Paid to Puerto Rico Corporations as Enacted in The American Jobs Creation Act
04/27/05
SIA's Cross-Border Subcommittee Comments Regarding The Consultation Paper: The Proposal For The Removal Of Barrier 1 Of The Giovannini Report
04/27/05
SIA Concerns Regarding Ongoing OECD Work on Rules for Allocating Global Income among Affiliated Entities and their Permanent Establishments
04/26/05
NYSE Letter On Proxy Over Reporting And Record Retention
04/20/05
TBMA Files Comment Letter on NASD Proposed Rule 2231 Regarding Confirmation Disclosures in Corporate Debt Securities Transactions
04/15/05
SIA Letter Regarding Request For Relief From Regulation SHO Marking Requirement For Pilot Securities
04/08/05
SIA Comments on Proposed Rule Change Relating to TRACE Market Data Fees
04/06/05
Comment on the MSRB's Proposed Questions and Answers Regarding the Application of Rule G-37 to Contributions to Political Party Committees and PACs
04/05/05
TBMA Comments on NASD Proposed Amendments to Rule 2320(a) Governing Best Execution
04/04/05
Comments to the SEC Regarding Confirmation Requirements and Point of Sale Disclosure Requirements for Transactions in Certain Mutual Funds and Other Securities, Reopening of Comment Period and Supplemental Request for Comments
04/01/05
Comment Letter on Clarification of Rule G-37
03/18/05
Comments Regarding Ammendments No. 1 and 2 to the Best Execution Rule
03/17/05
Letter To The President's Advisory Panel On Federal Tax Reform Applauding Efforts To Identify Unnecessary Distortions, Inefficiencies, And Complexity In The Current System As A Precursor To Exploring Possible Reform Models
03/09/05
Comment Letter Regarding Amendments to NASD Rule 2340 (Customer Account Statements)
03/09/05
SIA Comments On The SEC's SRO Governance And Transparency Proposal Concept Release Concerning Self-Regulation
03/08/05
TBMA Files Comment Letter to SEC on SRO Governance and Transparency Proposal
03/08/05
The Association Responds to SEC's Request for Comment in Asset-Backed Securities Adopting Release
03/04/05
Joint Letter By The FIA And The SIA To The SEC Regarding Rule Amendments, CBOE And NYSE Customer Portfolio And Cross Margining Requirements
03/01/05
Letter to IRS on Proposed Circular 230 Regulations
03/01/05
Comment Letter re JCT Report
03/01/05
SIA Comments Concerning The Proposed Regulations By The IRS And In Regards To Information Reporting Relating To Taxable Stock Transactions
02/28/05
TBMA Files Comment Letter with SEC Regarding FICC Rule Proposal on Trade Submission Requirements
02/25/05
SIA Comments on National Association of Securities Dealers, Inc. (''NASD'') New Rule IM-10308 Regarding Mediators Who Serve as Arbitrators
02/24/05
Comment Letter to Basel on Unsettled Transactions
02/18/05
The Dealer Accounting Committee of the SIA Offers Comments on the FASB's proposed FSP SOP 78-9-a, and EITF Issue No. 04-5, and the Draft Abstract for EITF Issue No. 04-5
02/15/05
The Capital Markets Committee Of The SIA Comments To The SEC On The Proposed Amendments To Regulation M, The Anti-Manipulation Rules Concerning Securities Offerings
02/15/05
The Capital Markets Committee Of The SIA Comments To The SEC On The Proposed Rules Of The NYSE And NASD Relating To IPO Allocations And Distributions
02/11/05
SIA Comment Letter to FDIC Regarding FDIC Whitepaper on Identity Theft
02/11/05
Comments to Advisory Committee on Civil Rules on Proposed Changes Regarding Electronic Discovery
02/07/05
The SIA Comments On The SEC's Reproposal Re: The Advisers Act And Release Entitled Certain Broker-Dealers Deemed Not To Be Investment Advisers
02/04/05
SIA Response To The Commission's Notice Soliciting Comments On The Collection Of Information Pursuant To SEC Recordkeeping Rules
02/01/05
File No. SR-NASD-2004-22 Proposed Rule Change by the National Association of Securities Dealers, Inc. Relating to the Corporate Financing Rule and Shelf Offerings of Securities
02/01/05
The SIA Comments On The SEC's ReProposed Regulation NMS Under The Securities Exchange Act Of 1934
02/01/05
Capital Markets Committee Of The SIA Submits Response To The NASD On The Notice To Members 04-83
01/31/05
TBMA Files Comment Letter in Regards to ABS Section of Securities Offering Reform Proposal
01/31/05
TBMA Submitts Comment Letter to SEC in Regards to Securities Offering Reform Proposal and Its Impacts on the Corporate Debt Markets
01/21/05
TBMA Files Comment Letter on NASD Corporate Financing Rule Proposal
01/20/05
Operations Committee of the SIA comments on NASD Notice To Members 04-80, in which the NASD solicits comment on proposed changes to the rules relating to the NASD's Order Audit Trail System ('OATS')
01/19/05
TBMA and SIA File Joint Comment Letter to Washington Utilities and Transportation Commission Rulemaking to Consider Financial Reporting Rules
01/19/05
BMA/SIA Comment Letter on Rulemaking to Consider Financial Reporting Rules
01/18/05
Comment Letter to Treasury on Fails
01/11/05
Association Comments on S&P Debt Derivative Profiles Program
01/11/05
Comments to the Bank of England re: Sterling Short-Term Interest Rates
01/11/05
SIA Letter With Attachment Regarding New IRS Code Section 965 And Request For Guidance On Several Issues