Proposed Amendments to the Free-Riding and Withholding Interpretation

Published on:
July 25, 1997

The Self-Regulation and Supervisory Practices and the Capital Markets Committees of the Securities Industry Association (SIA)* provides comments to the National Association of Securities Dealers, Inc. on the proposed amendments to the Free-Riding and Withholding Interpretation (IM-2110-1), which would revised and streamline the Interpretation.  SIA reiterates its concerns regarding the expensive internal procedures firms must employ to demonstrate compliance with the Interpretation, and also notes the Interpretation could be streamlined even further.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.

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