Unsolicited Transaction Exemption

SIFMA provides comments to the Tennessee Department of Commerce and Insurance (the Department) on Proposed Rule 0780-04-02-.16 Unsolicited Transaction Exemption.

SIFMA shares concerns that, while the proposed regulation is well-intentioned, it appears to create new documentation burdens that are not required by any other state and that will limit the likelihood that the exemption is actually used. For example, SIFMA believes that the proposal’s reference to an “Unsolicited Transaction Exemption Form” suggests that either the Department or the broker-dealers themselves will need to create a new, separate document that reiterates a host of information that is already readily available.