*Letters

SIA Submits Comments to the SEC on Proposed Rule Change Relating to Amendments to NASD Rule 3370

Published on:
August 24, 2005

The Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a proposed rule change relating to amendments to National Association of Securities Dealers, Inc. (NASD) Rule 3370, Release No. 34-52131; File No. SR-NASD-2005-093. Rule 3370 requires NASD member firms to make, and document on the order ticket certain affirmative determinations.

SIAshare its concerns with the SECthat the new Rule 3370would cause undesirable effects including:1) imposing new obligations on member firms; 2) adversely impacting member firms’ delivery versus payment (DVP) basis; and 3) negatively impacting member firms’ margin trading.

*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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