The Securities Industry Association (SIA)* provides comments to the National Association of Securities Dealers (NASD) on a proposal to expand its public disclosure program. SIA notes that raw data comparisons can be confusing or misleading, nominal settlements should not be used to trigger disclosure of archived information and that three unadjudicated complaints over a ten-year period is too low a threshold to trigger disclosure of archived information. SIA suggests that the NASD delay dissemination of comparative complaint information to the public unless the narrower retail sales comparison can be made. SIA also believes that the figure of $10,000 (settlements less than this number drop off the public disclosure system after two years) is too low and should be raised to reflect current economic conditions. They also urge the NASD to reconsider making settlements part of the triggering mechanism for archived information.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TMBA) in 2006.