The Investment Company Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a National Association of Securities Dealers, Inc. (NASD) proposed change to NASD Conduct Rule 2830 relating to non-cash compensation in connection with the sale of investment company securities, SEC Release No. 34-38993; File No. SR-NASD-97-35.  SIA strongly questions the need for revision of the current Conduct Rule 2830 at this time.

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