*Letters

Modernization of the Securities Exchange Act of 1934

Published on:
November 2, 2006

SIFMA provides comments to the Securities and Exchange Commission (SEC) on modernization of the Securities Exchange Act of 1934 (Exchange Act) Rule 17-a.  Rules 17a-4(b)(4) and 17a-4(f) address the SEC’s record retention requirements.  SIFMA responds to requests that stem from a meeting between SIFMA and the SEC staff on May 15, 2006.  SIFMA gives the SEC additional information regarding a sampling of SIFMA member firms’ current e-mail volumes and practices; proposes additional details regarding what business functions/departments would be covered under a “Registration Plus” approach for e-mail retention; and proposes possible alternatives to the current non-erasable, non-rewritable (WORM) requirement.

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