SIA Submits Comments to the SEC on a Proposal Relating to Interpretive Material Regarding the Use of Investment Analysis Tools

The Securities Industry Association (SIA)* provides comments to the Securities Exchange Commission (SEC) on a proposal relating to interpretive material regarding the use of investment analysis tools. SIA supports the National Association of Securities Dealers, Inc.(NASD) effort to update its rules to accommodate new technology and for recognizing the potential value of investment analysis tools to the investing public. SIA expresses concern that the NASD’s proposal placed unnecessary restrictions on technology that can be of enormous benefit to the investing public and which is already widely available to the public through unregulated channels. SIA also notes that applying the NASD’s prohibition on projections, originally intended to apply to marketed investments, to investment analysis tools had resulted in much confusion on the part of member firms because it appeared to contradict other statements, interpretations and rule language permitting such tools. Lastly, the broadened application of the prohibition has the effect of making the well-intended exception seem exceptionally narrow, unnecessarily burdensome to comply with, and of marginal value.

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