SIFMA provides comments to the National Conference of Insurance Legislators (NCOIL) on the proposed rulemaking clarifying the scope of the statutory prohibition against the disclosure of a Suspicious Activity Report (SAR) and the proposed related interpretative guidance that permits the sharing of a SAR among US affiliates of broker-dealers in securities, mutual funds, futures commissions merchants and introducing brokers in commodities.  SIFMA offers several comments and suggestions, including : all financial institutions subject to a SAR rule within the entities’ corporate organizational structure should be permitted to share a SAR.; Third party service providers retained by a Designated Entity should be expressly included in the definition of “agent” for purposes of accessing SAR databases; a recipient of SAR should be permitted to share a SAR with all affiliates within an organization structure; each organizational structure should be permitted to use its own procedures and processes to protect the confidentiality of a SAR among affiliates that are already subject to a SAR rule.  SIFMA also seeks clarification relating to the disclosure of a SAR to certain regulatory organizations and in the context of arbitration and reparations proceedings.