December 23, 2010

Re. Temporary Rule Regarding Principal Trades With Advisory Clients

Comment Letter (SIFMA)

SIFMA submitted comments to the SEC on a proposed rule that would extend temporary Rule 206(3)-3T under the Investment Advisers Act (IAA), for an additional two years beyond its scheduled expiration on Dec. 31, 2010. The rule establishes a means for broker-dealers to comply with § 206(3) of the IAA.

SIFMA strongly favors an extension of Rule 206(3)-3T, arguing that the principal trading relief in the rule is more favorable to investors than dealings solely on an agency basis. SIFMA further suggests the rule should be made permanent and expanded, and reiterates its support for a "uniform federal fiduciary standard for broker-dealers and investment advisers."

Please contact any of the following Cadwalader attorneys if you have any questions about this item:

Steven Lofchie; [email protected]

Maurine Bartlett; [email protected]

Jeffrey Robins; [email protected]


December 20, 2010

Cross Reference (links require a Cabinet subscription)

SEC Release IA-3118

IA Rule 206(3)-3T

Advisers Act § 206(3)

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