SIFMA’s Prime Brokerage Committee provides comments to the International Organization of Securities Commissions (IOSCO) on the Consultation Report on Hedge Funds Oversight. Comments on those aspects of the Consultation Report that directly impact prime brokers and/or other regulated counterparties (prime brokers) of hedge funds. SIFMA believes that a careful analysis of systemic risk leads to the necessary conclusion that while prime brokers – as is true for any significant participant in the financial markets – are an important factor in addressing systemic risk in a comprehensive fashion, they can not serve as a ersatz “regulator” of other market part.