2006 Comment Letters

12/27/06
Supplemental Comments Regarding Proposed Revision of Annual Information Return/Reports (RIN 1210-AB06)
12/20/06
Comments on Quote Mitigation Proposals Re: Penny Pilot Program Scheduled to begin in January 2007
12/18/06
Market Data Subcommittee of the SIFMA Tech. and Reg. Committee Appreciates the opportunity to comment on Amex's Market Data Rule Filing No. SR-Amex-2006-89 (Amex Depth-of-Book Data)
12/11/06
SIFMA Submits Comments on the Massachusetts Securities Division's Proposed Regulations on the Use of Senior Designations
12/07/06
SIFMA Files Comment Letter with NAIC Regarding Transparency
12/05/06
SIFMA reply to the portion of FSA Consultation Paper 06/18 relating to a proposed amendment to COB 7.18 on the Use of Dealing Commissions
11/30/06
Comments and Recs Re: New Discussion Option from the Joint Committee on Taxation to Require Brokers to Report to the IRS and to Investors the Adjusted Basis of Publicly Traded Securities that are Sold During the Preceding Year
11/16/06
SIFMA Suggested FAQ and Answers to Treasury on Qualified Charitable Distributions (QCDs)
11/14/06
Comments to SEC on Analyst Codification Filing Re: File Nos. SR-NYSE-2006-77 and SR-NASD-2006-112; Proposed Changes Relating to NYSE Rule 472 and NASD Rule 2711
11/13/06
Letter to Dept of Labor Re: Proposed Qualified Default Investment Alternative Regulation
11/03/06
SIFMA Operations Committee Comments On The NASD Proposed Rule Regarding Allowing Certain Institutional Customers To Elect Not To Receive Account Statements (File No. SR-NASD-2006-066)
11/02/06
Comments to the SEC Re: Modernization of Securities Exchange Act Rule 17a-4
11/01/06
Joint Comments Re: NASD Notice to Members 06-52, Proposed Amendments to Conduct Rule 2720
10/23/06
Comment Re: Proposed Regulations under Section 409A and as they Relate to Payments on Account of Conflicts of Interest
10/23/06
Executive Compensation Disclosure Comments Filed with SEC
10/19/06
Letter to the SEC Division of Market Regulation Re: Options Penny Pilot Program
10/16/06
Letter to the IRS Re: Chief Counsel Advisory Regarding Manufactured Overseas Dividends
10/12/06
Association Sends Letter to Department of Education on IG Nelnet Report
10/10/06
Letter Re: Questions Recently Issued by the FDIC for Public Comment Regarding Industrial Loan Corporations
10/05/06
Comments Re: New Proposed Regulations Addressing the Definition of Taxpayer for Purposes of Section 901
09/29/06
Comments Re: Proposed Rule Change Relating to Motions to Decide Claims Before a Hearing on the Merits
09/22/06
Comments Re: Notice 2006-26, Request for comments on draft amendments relating on Rule G-21; and Re: 529 Savings Plans
09/20/06
Comments Re: MSRB Notice 2006-19- Application of "Access Equals Delivery" Standard to Official Statement Dissemination for New Issue Municipal Securities
09/19/06
Comments Regarding Proposed Revision of Annual Information Return/Reports RIN 1210-AB06
09/19/06
Comments to DOL Regarding Proposed Revision of Annual Information Return/ Employee Benifit Reports
09/19/06
Comments to SEC RE: REG SHO with Appendix Attached: Pertinent Data on Fails from Reg SHO Proposing Release and OEA Memo
09/15/06
Association Supports Application of Electronic Disclosure of Official Statements for New Issue Municipal Securities
09/15/06
Association Comments on MSRB's Draft Procedures for Reporting Special Condition Indicators for Certain Special Trading Situations
09/15/06
Associations File Joint Comment Letter on Operating During a Pandemic
09/15/06
SIA response to the SEC request for comments on the collection of Electronic Blue Sheet data
09/15/06
Securities Industry Comments to NASD Notice to Members 06-31
09/07/06
Comments Re: SEC Guidance Regarding Client Commission Practices Under Section 28(e) of the Securities Exchange Act of 1934
09/07/06
TBMA Files Comment Letter on Student Loans
08/30/06
Association Supports Return to Previous Classification of Hybrid Securities
08/26/06
TBMA/AMF Send Letter on Senate Pension Bill
08/23/06
Comment Letter on Definition and Treatment of Hybrid Securities
08/18/06
SIA's Market Data Subcommittee of the Tech and Reg Committee Comment On Market Data Fee Rule Filing
08/18/06
SIA's Market Data Subcommittee of the Tech and Reg Committee Supplement June 30, Comments RE: NYSE Arca Filings and Respond to some Issues Raised by NYSE Arca In Its Letter Of July 25, 2006
08/09/06
Association Urges US Treasury To Carefully Weigh Costs & Benefits of Creating Securities Lending Facility
07/28/06
TBMA and ISDA Comment on GASB Preliminary Views on Accounting and Disclosure of Derivatives and Hedging Activities by Governmental Entities
07/20/06
Comments Re: (Release No. 34-54053; File No. SR-NASD-2003-168) Proposed Amendments 4 and 5 Relating to the Release of Information Through the NASD BrokerCheck
07/19/06
Comments Re: RFI to Assist The SEC In Compiling Data Pertaining To The Marketing, Sale And Delivery Of Financial Services/Products To Individual Investors By Broker-Dealers and Investment Advisers
07/19/06
Comment Letter to SEC Re: Variable Annuities Sales Practices and Supervisory Procedures
07/17/06
ICMA, ISDA and TBMA Jointly Respond to FSA Discussion Paper on Implementing MiFID's Best Execution Requirements
07/17/06
TBMA Submits Comment Letter to SEC Regarding NASD's Rule Change on Gifts and Business Entertainment Policy
07/14/06
The Market Data Subcommittee of the SIA Technology and Regulation Committee comments on Nasdaq proposed market data rules. (File Nos. SR-NASD-2006-056 and SR-NASD-2006-072)Trading and Compliance Data Package Proposal
06/30/06
The Market Data Subcommittee of the SIA Technology and Regulation Committee comments on NYSE Arca proposed market data rules. (File Nos. SR-NYSEArca-2006-21 and SR-NYSEArca-2006-23)
06/27/06
SIA Operations Committee Comments on the Proposed Rules Regarding the Requirement of Listed Securities to be Eligible for a Direct Registration System. (File No. SR-NYSE-2006-29; SR-NASDAQ-2006-008; and Amex 2006-40)
06/19/06
Association Renews Call For Public Dissemination of Information Regarding NAIC Classifications
06/16/06
Association Warns Proposal to Disclose Counterparty and Type of Trade Information Will Harm Investors and Liquidity
06/16/06
SIA Operations Committee Comments On The Proposed Rule Regarding Allowing Certain Institutional Customers To Elect Not To Receive Account Statements (File No. SR-NYSE-2005-90)
06/15/06
Industry Associations Commend Regulators for Revised Regulatory Guidance on Complex Structured Finance Activities
06/15/06
Joint Letter Re: Revised Interagency Statement on Sound Practices Concerning Elevated Risk Complex Structured Finance Activities
06/15/06
ASF Comment Letter Supports Revised Interagency Guidance on Complex Structured Finance Activities
06/15/06
Joint Letter Re: Revised Interagency Statement on Sound Practices Concerning Elevated Risk Complex Structured Finance Activities
06/09/06
SIA Request for Expedited Guidance Concerning New Tax Withholding and Information Reporting Requirements
06/08/06
Letter Submitted to SEC Regarding Derivatives Counterparty Financial Disclosures
06/02/06
Public Comment on Regulatory Issues Arising from Exchange Evolution
05/31/06
Letter to SEC Re: Proposed MSRB Interpretive Guidance Under Rule G-17 Regarding Customer Protection Obligations Relating To The Marketing Of 529 College Savings Plans
05/30/06
Comment Letter on New York State Lobbying
05/23/06
Comments to SEC RE: Notice of NASD Filing of Proposed Rule Change Relating to Position Limits and Position Reporting Obligations for Conventional Index and Equity Options
05/19/06
SIA Comment Letter to the SEC Raising Concerns About NASDAQ Application Regarding Business Ventures, and Requesting an Extension of the Comment Period on this Rule Proposal
05/16/06
SIA Comment Letter with Appendix on NYSE & CBOE Proposals on expanding the Portfolio Margining Pilot Program
05/11/06
Letter RE: AICPA Proposed Statement of Position (SOP), Clarification of the Scope of the Audit and Accounting Guide Audits of Investment Companies
05/08/06
Letter to New York Stock Exchange Regarding NYSE Information Memorandum 06-22
05/04/06
Association Believes NASD Proposal to Expand Authority to Exchange Transactions May Create Duplicate Regulation; Calls for Clarity
05/03/06
Letter to IRS Re: Comments On Proposed Regulations Under Section 1503(D) Of The Internal Revenue Code, Relating To The Certification Period For Dual Consolidated Losses
05/02/06
Letter Filed with SEC Re: Proposed NASD Rule 2290 Regarding Fairness Opinions File Number SR-NASD-2005-080; Release No. 34-53598
04/28/06
SIA further comments on NYSE OpenBook and Market Data Issues
04/20/06
Comment Letter on New York State Lobbying
04/10/06
Comments to the SEC Re: Proposed Amendments to Mutual Fund Redemption Fee Rule 22c-2 (Release No. IC-27255 File No. S7-06-06)
04/10/06
Comments to the SEC Re: Proposed Amendments to the Executive Compensation and Related-Party Disclosure Rules
04/07/06
Letter to the SEC re: Modernization of Securities Exchange Act Rule 17a-4 (Electronic Records & E-mail Retention) - Request for a Meeting
04/05/06
SIA Letter to SROs Regarding Reg NMS Information Needed from SROs
04/05/06
Joint Letter Re: Proposed Statement of Financial Accounting Standards, The Fair Value Option for Financial Assets and Financial Liabilities
03/28/06
The Financial Services Coordinating Council Letter of Concern Re: Breach of Security Legislation
03/27/06
SIA and TBMA Comments on the SEC's Approval Order On The Governance Changes In Connection With The NYSE - Archipelago Merger
003/24/06
Association Sends Letter to Fed Reserve on Guidance
03/24/06
SIA Letter to SEC Staff Recommending Regulation NMS Implementation Steps and Time Frames for Broker-Dealers
03/24/06
Comments to the SEC Re: Self-Regulatory Organizations; Options Clearing Corporation; Notice of Filing of a Proposed Rule Change To Revise Option Adjustment Methodology, File Number SR-OCC-2006-01
03/23/06
Joint Letter to the Senate Banking Committee expressing concern with some proposals to amend the Committee on Foreign Investments in the United States (CFIUS)
03/23/06
SIA Options Committee Comments to the SEC Re: Notice of Filing of Proposed Rule Change and Amendment No. 2,3 and 4 to Proposed Rule Change to Modify the Information Contained in a Directed Order on the BOX, File Number SR-BSE-2005-52A-4
03/14/06
SIA comments on the proposed Economic Sanctions Enforcement Procedures for Banking Institutions issued by the Office of Foreign Assets Control test
03/10/06
Comments on the Joint Forum of the Basel Committee on Banking Supervision High-Level Principles for Business Continuity (December 2005)
03/07/06
Comment Letter in Response to NASD Notice To Members and NYSE Rule Proposal, Relating to Member Firms Gifts and Business Entertainment Practices, Appendix Included with Comparison of NASD Proposed IM-3060 And NYSE Proposed Rule 350A
03/06/06
Joint Letter Re: Notice of Proposed Rulemaking on Anti-Money Laundering Special Due Diligence Programs for Certain Foreign Accounts
03/03/06
SIA and FIA Request Extension From FinCen to Implement Due Diligence Provisions for New Accounts Under Rule 312 of the USA Patriot Act
03/03/06
SIA comments on the OECD's Proposals for Improving Mechanisms for the Resolution of Tax Treaty Disputes
02/28/06
The SIA Comments on the Social Security Administration's December 30, 2005 Federal Register Notice (Vol. 70, No. 250) Regarding its Consent Based Social Security Number Verification Process
02/23/06
SIA and FIA Request From FinCen Clarification of Due Diligence Provisions for New Accounts Under Rule 312 of the USA Patriot Act
02/21/06
Letter Filed with the SEC on Amendments to the Tender Offer Best-Price Rule; Release Nos. 34-52968; IC-27193
02/17/06
Proposed New Part 302 of the Superintendent's Regulations (Reporting of Suspicious Transactions)
02/15/06
Letter from SIA Dealer Accounting Committee to Jean Cawley, First Vice President and Deputy General Counsel, the Option Clearing Corporation, Regarding Proposed Rule Change to Provide for Close-Out Netting
02/14/06
SIA Cross-Border Subcommittee comments to SWIFT on the Draft Protocol Recommendation for the Removal of Giovannini Barrier 1
02/13/06
Response To The SEC Request For Comments On Proposed Rule Relating To Internet Availability Of Proxy Materials
02/13/06
SIA Ad Hoc Portfolio Margining Committee Letter to the SEC with Comments on NYSE Proposal That Would Amend The Portfolio Margin Pilot Program in NYSE's Rule 431(g)
02/07/06
SIA Request for Extension of Electronic Blue Sheet Data Validation Compliance Date from the Intermarket Surveillance Group
02/02/06
SIA Letter Regarding Notice of Filing of Proposed Rule Change and Amendment Nos. 1, 2, 3, 4, 5 and 6 Relating to the New York Stock Exchange's Business Combination with Archipelago Holdings, Inc.
01/30/06
SIA's Tech & Reg Committee Follow Up Letter Outlines Concerns Re: aspects of NASDAQ Services Agreement
01/30/06
SIA letter to the Chairman, House Ways and Means Committee, Arizona House of Representatives in support for HB 2280, as amended (529 plan)
01/26/06
ICI, ACLI, IAA and SIA Comments to the Office Of Labor-Management Standards Regarding Proposed Amendments To Form LM-30 And Related Issues Concerning Taft-Hartley Pension Plans And LM-10 Reporting Requirements
01/26/06
SIA letter to Chairperson, Taxation Committee, Kansas State Capitol Expresses Strong Support For The Bill, HB 2573, Legislation That Extends Favorable State Tax Treatment To All Qualified 529 Plans
01/18/06
SIA Comments to the FCC Regarding Proposed Rulemaking under the Telephone Consumer Protection Act of 1992, as amended by the Junk Fax Protection Act of 2005
01/18/06
SIA Request to SEC for a Three-Week Deadline Extension For Comments On Proposed Governance Changes from the NYSE In Connection With Its Conversion To A For-Profit Entity
01/13/06
Association Warns Proposed Changes to MSRB Rule G-23 Will Restrict Competition and Harm Market
01/12/06
SIA Letter to Alabama Representative Richard J. Lindsey, Chairman of Education, Finance and Appropriations Committee, in Suppo rt of Amending HB62 to Extend Tax-Free Treatment to Any 529 Plan
01/10/06
Association Says Most Recent MSRB Interpretation Defining Solicitation of Municipal Securities Business Should Replace all Prior Interpretations