SIFMA submitted detailed comments to SEC Deputy Secretary Kevin O'Neill regarding the SEC's proposed recordkeeping, reporting, notification and security count requirements for security-based swap dealers ("SBSDs"), major security-based swap participants ("MSBSPs") and broker-dealers that enter into swaps. SIFMA noted that, in a number of places, the SEC Recordkeeping Proposal would prescribe recordkeeping or reporting requirements based on requirements in other rules that have been proposed by the SEC but have not yet been adopted; in particular, requirements relating to capital, margin and

The Asset Management Group of SIFMA ("SIFMA AMG") submitted comments to IOSCO regarding its consultation paper on good practices for reducing investment advisers' reliance on credit rating agencies ("CRAs") (the "Report"). In its letter, SIFMA AMG addressed one primary aspect of the Report: "the picture it paints of the asset management business and its operations." SIFMA AMG stated that the way in which the Report portrays the asset management business is "fundamentally inaccurate." The letter explained that the Report's position is based on the assumption that credit ratings have "financial

The SEC announced charges against 28 officers, directors and major shareholders for violating federal securities laws requiring them to promptly report information about their holdings and transactions in company stock. Additionally, six publicly traded companies were charged with contributing to filing failures. Nearly all of the 34 individuals and firms charged agreed to settle and pay financial penalties totaling $2.6 million. The charges, according to the SEC, stem from an enforcement initiative focusing on two types of ownership reports: those relating to Section 13(d) of the Securities

The Over-the-Counter ("OTC") Derivatives Regulators Group ("ODRG") issued a report that provides an update to the G20 on further progress in resolving OTC derivatives' cross-border implementation issues. The ODRG is made up of authorities with responsibility for OTC derivatives markets regulation in Australia, Brazil, the European Union, Hong Kong, Japan, Ontario, Quebec, Singapore, Switzerland and the United States. The report described two areas in which the ODRG is working to develop approaches to address cross-border issues: (i) potential gaps and duplications in the treatment of branches

The North American Securities Administrators Association ("NASAA") released the results of a pilot project designed to survey the cybersecurity practices of state-registered investment advisers, who account for more than half of the registered investment advisers conducting business in the United States. The project surveyed 440 registered investment advisers with assets under management of less than $100 million. The results indicated that 4.1 percent of responding firms indicated that they had experienced a cybersecurity incident, and 1.1 percent indicated that they had experienced theft