The Federal Regulation and Self-Regulation and Supervisory Practices Committees and the Compliance and Legal Division of the Securities Industry Association (SIA)* provide comments to the Securities and Exchange Commission (SEC) on proposed amendments to the books and records requirements set out in Rules 17a-3 and 17a-4 under the Securities Exchange Act of 1934 (the Exchange Act).  SIA notes the existing federal rules governing the regulation of broker-dealer books and records have served the industry well for over 50 years.  SIA share its belief that the comprehensive transformation of the federal books and records rules, as proposed, is prohibitively burdensome on the efficiency of the capital markets, the competitiveness of the U.S. securities industry and capital markets, and the process of capital formation.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.