Books and Records Requirements for Broker-Dealers
Published on:
March 31, 1997
PSA The Bond Market Association (TBMA)* provides supplemental comments to the Securities and Exchange Commission (SEC) on books and records requirements for broker-dealers, File No. S7-27-96. TBMA continues to strongly oppose the proposed rules on the basis that they would, among other things:
- impose excessive and unwarranted costs on broker-dealers, and ultimately, on investors;
- impose new substantive books and records requirements with insufficient demonstration of their need, and inadequate analysis of their impact and burden;
- effect a radical and counterproductive shift in the SEC’s historical oversight of books and records regulation, by adopting an inflexible, micro-managerial approach to the compliance function, and creating disincentives to effective self-regulation.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.