December 7, 2018

Via Electronic Mail

Ms. Emily Westerberg Russell
Senior Special Counsel
Division of Trading and Markets
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re: Request for No-Action Relief under Broker-Dealer Customer Identification Program Rule (31 C.F.R. § 1023.220) and Beneficial Ownership Requirements for Legal Entity Customers (31 C.F.R. § 1010.230)

Dear Ms. Russell:
On behalf of its member broker-dealers, the Securities Industry and Financial Markets Association (“SIFMA”) hereby requests that the staff of the Division of Trading and Markets (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) extend the no-action relief currently in effect with respect to the reliance provisions of the customer identification program rule applicable to broker-dealers (the “CIP Rule”) and the rule regarding beneficial ownership requirements for legal entity customers (the “Beneficial Ownership Rule”).

More specifically, under the conditions of a letter dated December 12, 2016 (the “2016 No-Action Letter”), Division staff has granted no-action relief to broker-dealers that rely on SEC-registered investment advisers (“RIAs”) to perform some or all of the requirements of the CIP Rule and the Beneficial Ownership Rule. No-action relief was originally granted with respect to the CIP Rule in 2004 and has since been extended a number of times. Under the 2016 No-Action Letter, the current relief, addressing the reliance provisions of both the CIP Rule and the Beneficial Ownership Rule, expires December 12, 2018. Because broker-dealer firms continue to rely on this relief, we urge the Division staff to continue to make it available.

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