Securities Information Processors and Operational Resiliency

SIFMA provides comments to the Securities and Exchange Commission (SEC) on review by the SEC of the operation of the Securities Information Processors (SIPs). SIFMA appreciates the Commission’s leadership in examining these important issues in light of the August 22, 2013 SIP outage that led to a halt in trading of Nasdaq-listed securities. The August 22nd events highlighted the critical nature of the SIPs in maintaining fair and orderly markets and emphasized the need for regulators and market participants to coordinate and collaborate to make sure the markets are operationally resilient and robust.

SIFMA supports the SEC’s direction to the self-regulatory organizations (SROs) to work& collaboratively on these issues with all market participants, including the broker-dealer SIFMA has initial points of view on the five workstreams that the Commission identified after the SEC’s September 12th meeting with the SROs. However, as this review process moves from preliminary concepts to concrete proposals, it is imperative that the broker-dealer community play an active role in developing proposals without simply waiting for public comment after proposals are filed with the Commission. The unique expertise and insight of the broker-dealer community complements that of the SROs. We believe the SROs should fully integrate the broker-dealer and investment community into their workstreams associated with the SEC request for review, as SIFMA believes such collaboration will greatly benefit and enhance the proposals that will be subsequently developed.