The Securities Industry Association (SIA)* provides comments to the Securities Exchange Commission (SEC) on a proposal relating to compliance programs of investment advisers and investment companies, Release Nos. IC-25925, IA-2107: File No. S7-03-03. SIA believes that the utilization of written compliance procedures developed and supervised by qualified compliance professionals, and the periodic review of such procedures to assure continued viability, are critical components of any effective compliance program. SIA supports the proposal to require written investment adviser compliance procedures, and to periodically review same, provided it is clarified that dual registrants may rely on integrated written procedures and may conduct periodic reviews of such procedures to satisfy the requirements of any adopted rule. SIA also supports an investment advisory fidelity bonding requirement, provided it conformed to the requirements to which dual registrants are already subject with respect to their broker-dealer operations.

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