Proposal Relating to the Exemption of Certain Foreign Brokers or Dealers

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed amendments to Rule 15a-6 for exemption of certain foreign brokers or dealers, Release No. 34-58047; File No. S7-16-08. The proposed amendments to Rule 15a-6 would eliminate regulatory obstacles to the efficient delivery of cross-border services by foreign securities firms to U.S. qualified investors. SIFMA supports the proposed new definition of a “qualified investor.” SIFMA believes some of the provisions are unnecessary and unwarranted, including: (1) those imposing a “foreign business test;” (2) custody requirements to qualify for exemptions; and (3) the requirement that a non-U.S. firm be regulated with respect to the proposed activities with U.S. qualified investors in their home market.