SEC Proposal Relating to Foreign Issuers

The Operations Committee of SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposal by The Depository Trust Company (DTC) on the eligibility of securities of foreign issuers for deposit and book-entry transfers through the facilities of DTC.  SIFMA believes the DTC should establish criteria and procedures for making older issues of unregistered Foreign Securities DTC-eligible. In addition SIFMA notes that older issues of unregistered Foreign Securities pose no additional risk to DTC or to the national clearance and settlement system. SIFMA believes that participants and the markets will benefit from making a wider range of unregistered Foreign Securities eligible for cost effective transfers and the risk management controls available through DTC facilities.