SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed rules to implement whistleblower provisions of Section 21F of the Securities Exchange Act of 1934 (Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act [Dodd-Frank Act]), File No. S7-33-10, Release No. 34-63237.  SIFMA believes that in some important respects the proposed rules do not go far enough to protect the critical role played by internal compliance reporting systems, and therefore weaken the overall system of prevention and detection.

On February 3, 2011, SIFMA and the Futures Industry Association (FIA) submitted comments to the Commodity Futures Trading Commission (CFTC) proposed rules for implementing whistleblower provisions, Section 23 of the Commodity Exchange Act, File No. 3038-AD04.