SIFMA provides comments to the New Jersey Department of Law & Public Safety on the New Jersey Securities Act.  The Uniform Securities Act (Act) was revised in 2002 (RUSA) to both harmonize the Act with the National Securities Markets Improvement Act of 1996 and the Securities Litigation Uniform Standards of 1998 and to modernize the Act with respect to significant changes in the technology of securities trading, regulation and international aspects of securities transactions.  To date, thirteen states have adopted RUSA.  In the interim while the State of New Jersey considers adopting RUSA, SIFMA recommends three specific secondary market transaction exemptions (non-issuer transactions) as they currently appear in RUSA.  Since the State of New Jersey is considering the New Jersey Securities Act, SIFMA requests the inclusion of the following exemptions: (1) investment grade securities; (2) foreign securities that are deemed marginable under the Board of Governors of the Federal Reserve System standards; and (3) transactions in managed accounts by federal covered investment advisers.