*Letters

SIA Submits Comments to the SEC on a Proposal to Clarify Insider Trading Rules

Published on:
April 28, 2000

The Securities Industry Association (SIA)* provides comments to theSecurities and Exchange Commission (SEC) on a proposal that would further clarify the scope of Rule10b5 relating to insider trading, File No. S7-31-99, Release No. 33-7787. SIA shares two fundamental concerns with the proposal. First, the affirmative defenses need to be broadened and clarified in some respects to address additional situations where the investor should be permitted an opportunity to demonstrate that possession of inside information was not a factor is his or her investment decision. Second, and more importantly, the enumerated defenses should not be exclusive.
*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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