SEC’s Ways to Access Disclosures Relating to Business Activities & Countries Designated as State Sponsors of Terrorism

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s concept release on whether to develop a mechanism to facilitate greater access to companies’ disclosures concerning their business activities in or with countries designated as State Sponsors of Terrorism, Concept Release Nos. 33-8860; 34-56803; File No. S7-27-07.  SIFMA believes the tool that was implemented during the summer of 2007, and subsequently suspended, inappropriately involved the SEC in foreign policy and national security matters, was unfairly detrimental to companies, was damaging to the role the SEC has historically played in enhancing investor confidence in the U.S. capital markets, and provided no new additional public information. It is SIFMA’s view that any similar mechanism including data tagging would have the same inherent flaws.  SIFMA urges the SEC to refrain from reinstituting a website tool for review of information about activities of SEC registrants relating to countries designated as State Sponsors of Terrorism.