Draft Strategic Plan for Fiscal Years 2026–2030

Summary

SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) on the Draft Strategic Plan for Fiscal Years 2026–2030 (Draft Plan).

Excerpt

SIFMA strongly supports the Draft Plan’s focus on the SEC’s three-part mission: protecting investors; maintaining fair, orderly, and efficient markets; and facilitating capital formation. We also support the Draft Plan’s emphasis on modernizing the regulatory framework, enhancing stakeholder engagement, facilitating compliance, grounding regulation in rigorous cost-benefit analysis, and ensuring that enforcement is focused on clear violations of established law. SIFMA has a strong interest in ensuring that the Commission’s strategic objectives are implemented in a way that promotes these goals.

The Draft Plan rightfully recognizes that the U.S. capital markets are evolving rapidly due to emerging technologies, changing investor expectations, new business models, and global competition. It also recognizes that legacy rules must be reassessed to ensure that they remain fit for purpose and do not impose unnecessary burdens or needless friction. SIFMA urges the Commission to use the Draft Plan as a roadmap for concrete action.

I. Executive Summary

SIFMA urges the Commission to use the Draft Plan as a roadmap for concrete action across the following priorities:

• Regulatory Modernization (Objectives 1.3, 2.3, 3.2). The Commission should: establish electronic delivery as the default standard for investor documents; recalibrate communications retention to focus on records with genuine regulatory value; modernize fixed income cross-trading under Rule 17a-7; and review mutual fund quorum rules to reduce unnecessary shareholder costs.
• Stakeholder Engagement (Objective 2.1). SIFMA appreciates the Commission’s industry engagement and recommends that the SEC institutionalize engagement before, during, and after rulemaking — including roundtables, implementation guidance, and post-implementation reviews — with particular attention to rapidly evolving areas such as AI, digital assets, and cybersecurity.
• Enforcement Discipline (Objective 2.2). The Commission should confine enforcement to clear violations of established law. In unsettled or evolving areas, the Commission should proceed through notice-and-comment rulemaking with rigorous economic analysis and adequate implementation periods and providing interpretive guidance rather than regulation by enforcement.