Supplemental Comments on Digital Asset Markets (Joint Trades)
SIFMA and joint associations provided additional comments to the President’s Working Group (PWG) on Digital Asset Markets Chair in support…
April 11, 2022
Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-1090
Re: File No. S7-06-22; Modernization of Beneficial Ownership Reporting (the “Proposal”)
Dear Ms. Countryman:
The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG”)2 appreciates the opportunity to provide comments to the Securities and Exchange Commission (the “Commission” or “SEC”) on the above-referenced Proposal to:
The Proposal makes a number of changes to a regulation that has functioned very well to implement the relevant statutory provisions of Section 13 of the Exchange Act. In our view, what has been billed as a “modernization” of existing rules is actually a dramatic expansion of scope and obligations – many of which seem unrelated to a data-driven identification of problems requiring attention. While the changes may be characterized as intended to address abuse, the anti-evasion rules already present in Regulation 13D-G have
1 Modernization of Beneficial Ownership, 87 Fed. Reg. 13846.
2 SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.