SEC’s Securities Lending & Short Sale Roundtable

SIFMA’s Securities Lending Division and the Committee on Securities Lending of the Risk Management Association (RMA) provides comments to the Securities and Exchange Commission (SEC) on the current state of the U.S. securities lending markets, notions of a centralized marketplace for securities lending as well was a securities lending central counterparty, SEC Files Nos. 4-590, S7-30-08 and S7-08-09. SIFMA believes the differences between the securities lending markets and cash markets should be considered in determining whether a centralized marketplace or central credit counterparty (CCP) for securities lending would be effective. Other issues to foster a successful securities lending CCP also addressed within. Specific comments relative to the Quadriserv Proposal appear in Appendix I.