Request to Extend Certain Temporary Exemptions to the Treatment of SBS under the Exchange Act
Summary
This letter responds to the request by staff of the U.S. Securities and Exchange Commission (the “Commission”) that SIFMA supplement its November 2018 submission regarding the treatment of SBS as Securities under the Exchange Act by providing additional details regarding certain of the exemptions and guidance requested in that submission. In particular, we identify which of our requests related to Unlinked Temporary Exemptions and provide additional details regarding those requests. We also recommend a transition period before the expiration of any Unlinked Temporary Exemptions.
Excerpt
Carol McGee
Assistant Director
Office of Derivatives Policy, Division of Trading and Markets
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: Order Extending Until February 5, 2019, Certain Temporary Exemptions under the Securities Exchange Act of 1934 in Connection with the Revision of the Definition of “Security” to Encompass Security-Based Swaps and Request for Comment (Release No. 34-82626; File No. S7-21-11)
Dear Ms. McGee:
This letter responds to the request by staff of the U.S. Securities and Exchange Commission (the “Commission”) that the Securities Industry and Financial Markets Association (“SIFMA”)1 supplement our submission dated November 8, 2018 (the “November 2018 Submission”)2 regarding the above-captioned release (the “2018 Extension Order”) by providing additional details regarding certain of the exemptions and guidance that we requested in that submission. In particular, we identify which of our requests related to Unlinked Temporary Exemptions (as defined below) and provide additional details regarding those requests. We also recommend a transition period before the expiration of any Unlinked Temporary Exemptions.