SIFMA and FSI Submit Comments to the Virginia SCC with Joint Legal Analysis on Federal Preemption of State Law

SIFMA and the Financial Services Institute ("FSI") provided joint legal analysis to the Virginia State Corporation Commission ("Virginia SCC") in support of the view that the point-of-sale disclosure requirements in Rule 21 VAC 5-20-280 A(32) of the Virginia Register of Regulations are preempted by, among other things, Section 103 of the National Securities Markets Improvement Act of 1996 ("Broker-Dealer Exemptions from State Law"), which preempts state regulation of broker-dealer capital, margin, books and records, bonding and reports.

See: SIFMA and FSI Comment Letter.