*Letters

Trade Reporting Obligations for Transactions in Foreign Equity Securities

Published on:
August 23, 2007

SIFMA provides comments to the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) on trade reporting obligations for transactions in foreign equity securities. Release No. 34-55745, File No. SR-NASD-2007-030.  SIFMA believes that an additional measure should be taken in connection with a point raised by FINRA regarding American Depository Receipt (ADR) swap or “cross book” transactions.  SIFMA recommends the proposal be further amended to exempt these transactions from the reporting requirements of National Association of Securities Dealers (NASD) Rule 6620.

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