Modernizing Compliance for a New Regulatory Era

Remarks as Prepared for Delivery at the 2026 C&L Annual Seminar

Good morning and welcome. I’m Saima Ahmed, General Counsel of SIFMA.

Every year, we at SIFMA are reminded just how critical this conference and its attendees—all of you– are to the financial services industry. Where else do we have nearly 2000 compliance and legal professionals gathered in one place, devoting 3 plus days to ask and try to answer difficult and ever changing questions about how best to keep our markets safe?

We have a lot to talk about over the next few days and I am so excited to be here with all of you.

Last year, when we gathered in Austin, we spoke about uncertainty — a new administration, a shifting regulatory landscape, and what that might mean for our industry.

This year, it’s a different scenario. SEC Chairman Paul Atkins has described this moment as “a new day at the SEC.”

If this is indeed a new day, perhaps it is an opportunity for a change in our regulatory environment for which many of us have long advocated: Modernization. Not deregulation for the sake of deregulation and certainly not retreat from investor protection.

But modernization — bringing regulatory frameworks into alignment with how markets, technology, and compliance systems actually function in 2026.

Allow me to briefly highlight three areas where SIFMA sees real opportunity – these and other topics will be a focus over the next several days – both on this stage and in our invaluable breakout sessions

Records Retention Reform

We spoke last year about the books and records framework and the uncertainty surrounding the meaning of “business as such.” That conversation is far from over.

The current records retention regime was drafted in an era that did not contemplate cloud-based systems, collaborative workspaces, encrypted messaging platforms, or AI-enabled monitoring tools. Yet firms today are expected to capture and retain an ever-expanding universe of communications, going far beyond what was ever contemplated as necessary for investor protection and resulting in more risk than benefit for the industry.

In our view, a new regulatory day should mean clarity. It should mean a framework that clearly defines what must be retained and provides workable compliance pathways even as technology and methods of communication continue to evolve. And it should recognize good-faith supervisory systems by providing a safe harbor rather than imposing a strict liability standard for what is- – and what, inadvertently, may not be – retained.

Compliance professionals should not be left guessing at the contours of their obligations.

Collateral Consequences & the Waiver Process

A second area where modernization is both necessary and achievable is the SEC’s approach to the process of the granting of waivers from automatic statutory disqualifications that are triggered when Enforcement actions are settled or otherwise resolved.

These are called collateral consequences. But as anyone who has settled an SEC Enforcement matter knows all too well, the consequences can be quite severe, including for capital formation and growth, if the waivers are not timely granted.

I want to take a moment to thank the SEC for the changes they have already made since last Fall to make this process fairer and more predictable. Respectfully, we ask that the Commission continue to take steps to bring greater transparency, timeliness, and consistency to the waiver process.

For legal and compliance officers advising boards and senior management, predictability matters.

E-Delivery & Communications Modernization

A third area where reforms are long overdue is e-delivery and communications modernization.

Most customers communicate with their financial professionals electronically. Yet regulatory frameworks often assume paper-first delivery models that increase cost and operational risk without improving investor engagement.

Modernizing e-delivery rules would enhance investor access to their account information, be more efficient, and afford greater security for investor accounts.

This is a practical reform that benefits customers and compliance departments alike. And for those who prefer paper, all they have to do is opt-out of e-delivery.

Conclusion

On these and other topics you will hear about over the next few days, we are very encouraged by the tone we are hearing — including as recently as just a few days ago at SEC Speaks– about clarity, cost-benefit discipline, and regulatory harmonization across agencies.

Before we begin the program, I want to thank Mark Seffinger and Karen O’Toole for their leadership in developing an outstanding program. I also want to thank the Compliance & Legal Society planning committee for their tireless efforts putting together this terrific conference. And a big thank you to the many regulators who are joining us — we greatly value the dialogue.

And of course, thank you to our moderators, speakers, sponsors, and attendees. Year after year, it is your engagement that makes this conference what it is.

And now, it is my privilege to welcome SIFMA’s President and CEO, Ken Bentsen, to the stage for a conversation with SEC Chairman Paul Atkins about what this “new day” at the SEC means for all of us. Thank you.