Market Access Rule Proposal

SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding the SEC’s proposal to adopt a rule requiring risk management controls for broker-dealers with market access under the Securities Exchange Act, Release No. 61379, File No. S7-03-10. The Proposal requires broker-dealers with access to trade directly on an exchange or an alternative trading system to implement risk management controls and supervisory procedures designed to manage the financial, regulatory, and other risks of this business activity. SIFMA considers that the rule should not be adopted until significant complex issues are addressed. In particular, the proposal’s simple structure raises complex issues regarding its application to well-established industry practices, which do not themselves involve heightened systemic risk concerns.