The Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on the SEC’s release, Certain Broker-Dealers Deemed Not to be Investment Advisers, File No. S7-25-99; Release Nos. 34-50980; IA-2340.  SIA supports the central position of the rule that an Exchange Act-registered broker-dealer’s offering its customers the alternative of paying a fee rather than a commission should not result in the broker-dealer’s becoming subject to the provisions of the Advisers Act.

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