Request for No-Action Relief under Broker-Dealer CIP Rule and Beneficial Ownership Requirements for Legal Entity Customers
Summary
SIFMA letter requesting the Division of Trading and Markets of the U.S. Securities and Exchange Commission (SEC) extend the no-action relief currently in effect with respect to the reliance provisions of the customer identification program rule applicable to broker-dealers (31 C.F.R. § 1023.220) (the “CIP Rule”).
See Related: Request for No-Action Relief under Broker-Dealer Customer Identification Program Rule and Beneficial Ownership Requirements for Legal Entity Customers – December 7, 2018
Securities and Exchange Commission (SEC) Response: No-Action Relief under Broker-Dealer CIP Rule and Beneficial Ownership Requirements for Legal Entity Customers – December 12, 2016
Excerpt
December 9, 2016
Via Electronic Mail
Ms. Emily Westerberg Russell
Senior Special Counsel
Division of Trading and Markets
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Request for No-Action Relief under Broker-Dealer Customer Identification Program Rule (31 C.F.R. § 1023.220) and Beneficial Ownership Requirements for Legal Entity Customers (31 C.F.R. § 1010.230)
Dear Ms. Russell:
On behalf of its member broker-dealers, the Securities Industry and Financial Markets Association (“SIFMA”) hereby requests that the staff of the Division of Trading and Markets (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) extend the no-action relief currently in effect with respect to the reliance provisions of the customer identification program rule applicable to broker-dealers (31 C.F.R. § 1023.220) (the “CIP Rule”). Under the conditions of a letter dated January 9, 2015 (the “2015 No-Action Letter”), the current relief expires on January 9, 2017. Broker-dealer firms continue to rely on the no-action relief, which was originally issued in 2004, and urge the Division staff to continue to make it available.