Broker Dealer Regulation - Reporting Requirements - Comment Letter - SIFMA - August 25, 2011
|Proposal Date||Final Rule Issue||Effective Date, SIPC Reports||Effective Date, SEC Reports|
|June 27, 2011||August 21, 2013||December 31, 2013||June 1, 2014|
August 25, 2011
In the comment letter, SIFMA comments on the following topics:
- "the definitions of 'material non-compliance' and 'material weakness in the Proposed Amendments;
- the proposed requirement that an auditor disclose any 'material modification' that should be made to the Exemption Report;
- the access to audit documents and auditors granted to the Commission and DEA examination staff under the Proposed Amendments;
- the proposed Form Custody; and
- certain costs associated."
SIFMA also provides a list of requested clarifications regarding form custody and suggests that the first Form Custody filing should happen no earlier than three quarters after the final rule effective date.