Regulation Best Interest (Reg BI)
Summary
SIFMA provided comments to the SEC on its proposed Regulation Best Interest (Reg BI). The SEC proposed a new rule under the Securities Exchange Act of 1934 (Exchange Act) establishing a standard of conduct for broker-dealers and natural persons who are associated persons of a broker-dealer when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. SIFMA expressed support for the proposal and offered suggestions to ensure it most efficiently accomplishes its stated goal of protecting investors.
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Excerpt
August 7, 2018
Via E-Mail to rule-comments@sec.gov
Brent J. Fields
Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
Re: 1) Regulation Best Interest (SEC Release No. 34-83062; File No. S7-07-18);
2) Form CRS Relationship Summary, Amendments to Form ADV, Required Disclosures in Retail Communications and Restrictions on the use of Certain Names or Titles (SEC Release No. 34-83063; IA-4888; File No. S7-08-18); and
3) Proposed Commission Interpretation Regarding Standard of Conduct for Investment Advisers; Request for Comment on Enhancing Investment Adviser Regulation (SEC Release No. IA-4889; File No. S7-09-18)
Dear Mr. Fields:
The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the above-captioned proposals (each a “Proposal” and collectively, the “Proposals”). SIFMA supports and commends the Securities and Exchange Commission’s (“SEC” or “Commission”) objectives of enhancing investor protection while at the same time preserving investor access to transaction-based advice and a variety of investment products. We have been supportive of the SEC’s attention to this important investor protection initiative for almost a decade; we want to remain constructive participants in the process and hope you find our response informative and helpful.
1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate on legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.