The Institutional Brokerage Committee of SIFMA provides comments to the Ontario Securities Commission, the British Columbia Securities Commission, the Alberta Securities Commission, the Saskatchewan Securities Commission, the Manitoba Securities Commission, the New Brunswick on Client Brokerage Commissions, the Securities Office – Prince Edward Island, the Nova Scotia Securities Commission, the Securities Commission of Newfoundland and Labrador, the Registrar of Securities – Northwest Territories, the Registrar of Securities – Nunavut, and the Registrar of Securities, Yukon Territory on a proposal on the use of client brokerage commissions as payment for order execution services or research services and companion policy 23-102- CP, Notice of Proposed National Instrument 23-102. The Canadian Securities Administrators (CSA) sought input on the proposal.  SIFMA supports the CSA goal of achieving cross-border compatibility in the regulation of client commission arrangements, and believes that the CSA has been largely successful in this. SIFMA suggests that the CSA take into account the Securities and Exchange Commission (SEC) timetable on amendments to Form ADV in setting their own timetable.