SIFMA Weighs In on SEC Four Year Strategic Plan

SIFMA called on the SEC to treat its draft strategic plan as a blueprint for action, pressing the agency to modernize outdated rules, rein in regulation-by-enforcement, and tighten its own cybersecurity practices.

In comments on the draft strategic plan for fiscal years 2026 through 2030, SIFMA recommended the following:

• Regulatory modernization: SIFMA asked the SEC to make electronic delivery the default for investor documents, streamline communications retention rules, update fixed income cross-trading and revisit mutual fund quorum requirements.
• Stakeholder engagement: SIFMA asked the SEC to formalize industry engagement throughout the rulemaking process - roundtables, implementation guidance, post-rule reviews - especially for fast-moving areas like AI, digital assets, and cybersecurity.
• Enforcement discipline: SIFMA urged the SEC to limit enforcement to clear-cut violations and use rulemaking (not enforcement actions) to address novel or unsettled issues.
• Retrospective review: SIFMA asked the SEC to reassess communications retention rules, statutory disqualification waivers, Reg NMS/Rule 611 and best execution, and the Consolidated Audit Trail ("CAT") to cut outdated or redundant requirements.
• SEC cybersecurity: SIFMA pressed the SEC to meet the same data-security standards it imposes on industry, limit data collection/retention, and set clear breach response protocols.

In the draft strategic plan, SEC Chair Paul Atkins directed the agency to focus its efforts on supporting innovation, easing capital raising, refocusing enforcement on clear violations of law, and improving operations.

Under the plan, the SEC said it will set clearer rules for digital assets and distributed ledger technology, clarify when securities law applies, and enable tokenized offerings. On capital raising, the SEC said it would work to widen access to private markets and simplify disclosure. On enforcement, the SEC said it would focus on clear violations of law, especially fraud, deception, and market manipulation. The SEC said it was reviewing existing rules, including those on foreign private issuers, quarterly reporting, private fund reporting, and executive pay. On improving operations the SEC noted recent supervisor and staff departures and said it will incorporate new technologies and changes to employee performance management.