SIFMA provides comments to the Securities and Exchange Commission (SEC) on large trader implementation issues for broker-dealers, SEC Rule 13h-1.  On April 20, 2012, the SEC took action to delay implementation of the broker-dealer duties under Rule 13h-1 (the April Order). The April Order temporarily exempted registered broker-dealers from Rule 13h-1’s recordkeeping and reporting requirements until November 30, 2012 for a certain limited category of transactions (Phase I) and temporarily exempted registered broker-dealers until May 1, 2013 from recordkeeping, reporting and monitoring requirements for all remaining transactions subject to Rule 13h-1 (Phase II).

While the April Order was welcomed by SIFMA and its members, it left unresolved many of the central implementation issues associated with Rule 13h-1 that we have raised in meetings with the SEC staff.

SIFMA raised significant implementation issues in a previous correspondence on March 29, 2012.