SIFMA and the American Securitization Forum (ASF) submitted the comments to the CFTC requesting relief to address "legacy" structured finance transactions. The groups stated that there are factors that distinguish these financings from those done on a prospective basis, which would therefore lessen the CFTC's regulatory interests and justify regulatory relief on a broader basis. A draft exemptive order was submitted for purposes of discussion (included in the letter). The structures to which the relief would apply are as below: "Legacy Entity" means an entity, regardless of its legal form
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In a position paper, SIFMA and the accounting firm Ernst and Young assessed the current state of corporate action announcement and dissemination policies in the United States and called for more industry standardization.
SIFMA and FIA urged the FTC not to adopt its proposed "Non-Compete Clause Rule," which would effectively prevent employers from implementing non-compete clauses.
SIFMA and the Financial Information Forum urged the SEC to better understand the "magnitude" of the costs associated with changing the funding model for the National Market System Plan Governing the Consolidated Audit Trail.
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.