*Letters

Jointly Proposed Regulation R

Published on:
March 26, 2007

SIFMA provides comments to the Securities and Exchange Commission (SEC) and the Federal Reserve Board of Governors (Fed) on proposed Regulation R and the definitions of terms and exemptions relating to the broker exceptions for banks; File No. S7-22-06; Docket No.R-2174.  SIFMA addresses what it believes as: 1) the unnecessary requirements for institutional and high net worth exemptions imposed by Proposed Exchange Act Rule 701; 2) the need for a safe harbor for broker-dealers similar to that proposed for banks; and 3) the need to coordinate the effective date of Regulation R with necessary amendments to NASD Rule 3040.

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