The Over-The-Counter (OTC) Derivative Products Committee of the Securities Industry Association (SIA)* provide comments to the Securities and Exchange Commission (SEC) on a proposal regarding OTC Derivatives Dealers, File No. S7-30-97. The proposed adoption of rules and rule amendments under the Securities Exchange Act of 1934 that would be applicable to qualifying entities who engage in certain OTC derivatives activities, but do not engage in the full range of securities activities typically associated with “brokers” or “dealers.” *SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.