FSA Discussion Paper About Short Selling

SIFMA, along with the London Investment Banking Association (LIBA), International Swaps and Derivatives Association (ISDA), and International Securities Lending Associations (ISLA), provides comments to the Financial Services Authority (FSA) on Discussion Paper 09/1 on Shorts Selling (DP). SIFMA has given answers to the specific questions posed in the DP which may be found in the attached Annex 1. In addition, SIFMA poses a number of overarching comments relating to the need for a more internationally consistent approach to the regulation of short selling and the need for such regulation to have clear objectives that are proportionate to the costs of achieving them.