SIFMA Statement on Amended SEC Rule 15c2-11

Washington, D.C., November 30, 2022 – SIFMA today issued the following statement from president and CEO Kenneth E. Bentsen, Jr. on amended Rule 15c2-11 in relation to fixed income securities issued today by the Securities and Exchange Commission (SEC):

“We are pleased the SEC has recognized the potential harm that applying the public disclosure requirements of Rule 15c2-11 to the 144A market would have caused to U.S. companies and investors.  The 144A market is currently relied upon by thousands of corporate and asset-backed securities issuers to raise capital and fund consumer lending, and previous staff guidance from the SEC would have compromised the ability of many issuers to access this market beginning in January 2023.

“We note that the relief is not permanent. We continue to believe that if the SEC wishes to apply this rule, which was designed for equity markets, to the fixed income markets, it should do so through a public and deliberative proceeding via Commission rulemaking, with an opportunity for public comment and a comprehensive cost benefit analysis.”


SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.

SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).