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Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report

Summary

SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) relating to the compliance dates of certain new requirements included in Securities and Exchange Commission Release No. 34-101925 which incorporates various rule amendments impacting the submission of certain forms, reports, and notices, in some cases using structured data, provided by broker-dealers, security-based swap dealers, and major security-based swap participants on the Commission’s Electronic Data Gathering, Analysis, and Retrieval system.

PDF

Submitted To

SEC

Submitted By

SIFMA

Related Committee(s)

  • Swap Dealer Committee

Date

13

May

2025

Excerpt

May 13, 2025

By electronic mail

Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: File Number S7–08–23: Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 is submitting this letter on behalf of our members relating to the compliance dates of certain new requirements included in Securities and Exchange Commission (“Commission”) Release No. 34-101925 (“Final Rule”) which incorporates various rule amendments impacting the submission of certain forms, reports, and notices, in some cases using structured data, provided by broker-dealers, security-based swap dealers (“SBSDs”), and major security-based swap participants (together with SBSDs, “SBS Entities”) on the Commission’s Electronic Data Gathering, Analysis, and Retrieval (“EDGAR”) system.2 SIFMA is requesting a 12-month extension of the relevant deadlines as described below.3 We are happy to work with the Commission on the legal form of any such relief.

I. Summary of New Filing Requirements

The Final Rule requires certain forms to be filed or submitted on EDGAR, with most to be provided in a structured, machine-readable data language:

  • Annual reports (and related annual filings) filed by broker-dealers (including over the counter derivatives dealers) and SBS Entities on Form X-17A-5 Part III;
  • The risk assessment reports filed by certain broker-dealers on Form 17-H; and
  • The notices and reports provided to the Commission by SBS Entities under Exchange Act Rules 15fi-3(c), 15fk-1(c)(2)(ii)(A) and 3a71-3(d)(l)(vi).
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  1. 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). For more information, visit http://www.sifma.org. [↩]
  2. 90 FR 7250 (January 21, 2025). [↩]
  3. We are not requesting a delay in compliance deadlines for other provisions of the Final Rule that do not relate to EDGAR submissions, such as amendments to FOCUS report requirements to align with current capital requirements or technical amendments to the Part IIC to fix errors and omissions, or related signature and notarization requirements. [↩]

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