Broker Dealer Regulation - Reporting Requirements - Comment Letter - SIFMA - August 25, 2011

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Dodd-Frank Timeline, Broker-Dealer Reports, SEC
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

Broker-Dealer Reports
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.