Modernization of the Securities Exchange Act of 1934

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.