*Letters

Publication or Submission of Quotations Without Specified Information

Published on:
May 15, 2026
Submitted to:
SEC
Submitted by:
SIFMA and SIFMA AMG
File Number:
S7-2026-08
Issue:
Committee:

Summary

SIFMA and SIFMA AMG provided comments on the Securities and Exchange Commission’s (SEC) proposed amendments to Exchange Act Rule 15c2-11 (the “Proposal”). SIFMA thanks the Commission for taking this important step and for responding to concerns that market participants have raised for several years regarding the current scope of Rule 15c2-11.

Excerpt

The Proposal would revise Rule 15c2-11 to refer only to “equity securities,” as defined in Exchange Act Rule 3a11-1, without otherwise changing the rule’s substantive information- gathering and review requirements. This letter discusses the Proposal as it relates to fixed-income securities, and SIFMA expects to submit a follow-on letter addressing additional recommendations regarding other types of securities, including issues raised by the proposal’s incorporation of the Rule 3a11-1 definition of “equity security.”4

SIFMA strongly supports revising Rule 15c2-11 so that it explicitly applies only to equity securities and no longer can be interpreted to scope in fixed-income products. The proposal is a constructive and important correction that appropriately aligns the rule with the manipulative trading concerns historically associated with the over-the-counter equity markets, rather than fixed-income markets including Rule 144A debt, asset-backed securities (“ABS”), and municipal securities. The Commission itself recognizes in the proposing release that the regulatory concerns underlying Rule 15c2-11 were manipulative schemes observed in the OTC equity markets, particularly involving issuers with little or no business activity or assets, and that the rule was designed to prevent broker-dealers from initiating market-making activity critical to those schemes. 1

SIFMA is not repeating here the full litany of arguments against the Commission’s 2021 decision to begin to enforce the Rule in fixed income markets as set forth in the SIFMA/SIFMA AMG letter dated March 2, 2026, which SIFMA incorporates by reference and has attached to this letter. 2

  1. Proposal, supra n.3, at 13244.
     
  2. Letter from Christopher B. Killian, Managing Director, SIFMA and Lindsey Weber Keljo, Managing Director, SIFMA AMG (Mar. 2, 2026)
    (“SIFMA Letter”).
     

Details

More Content

  • Letters
    Jun 23, 2026

    Capital Formation Legislative Package (Joint Trades)

    SIFMA and other trade groups urge the Senate Committee on Banking, Housing, and Urban Affairs to advance and introduce a capital formation package with key provisions this year.
  • Letters
    Jun 22, 2026

    Concept Release on CAT and Other Audit Trails and Data Sources

    SIFMA comments on the SEC’s concept release supporting its review of CAT, audit trails, and data sources used in U.S. securities market regulation.
  • Letters
    Jun 18, 2026

    Proposed Rule Change to Adopt FINRA Rule 4321 and Amend FINRA Rule 4560

    SIFMA comments to the SEC in response to the filing by FINRA to amend FINRA Rule 4560 (Short-Interest Reporting) and to adopt FINRA Rule 4321 (Allocations of Fail to Deliver Positions).

Get the latest trends, stats, and research on financial markets and securities.