SEC Rule 206(3)-3T’s Sunset Date Until 2014

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Temporary Rule Regarding Principal Trades with Certain Advisory Clients,  Release No. IA-3483; File No. S7-23-07. The proposal would amend Rule 206(3)-T (the Rule) under the Investment Advisers Act of 1940 to extend the Rule’s sunset date by two years from December 31, 2012 to December 31, 2014. SIFMA strongly supports extending the Rule, but also recommends that the SEC consider extending the Rule for a longer period of time of up to five years in order to give the SEC adequate time to consider broader rulemaking regarding the applicable standard of care for broker-dealers and investment advisers under Section 913 of the Dodd-Frank Act, as well as time to adopt and implement more permanent regulation of principal trading and prevent uncertainty caused by the need for additional extensions in the future.