Gardner, managing director and associate general counsel at J.P.Morgan and chair of the SIFMA
committee, doesn't see the need for preapproval of oral communications either.
said its best interest standard "could be articulated, for example, through amendments" to existing FINRA rules, "as approved by the SEC," and in a way that would be consistent "not only with SIFMA
's historical position" and with Dodd-Frank Act's Section 913, but also with the "best interest standard set forth in the DOL's [best interest contract exemption], and without certain conditions and requirements currently contained" in that exemption.
At another SIFMA
event--the Market Structure Conference, held in late spring in New York--Annette Nazareth, partner, Davis Polk & Wardwell LLP, Washington, D.C., and New York, and a former Securities and Exchange Commission (SEC) commissioner, addressed the proposal to create a systemic risk regulator, a.k.a.
Bleier noted that SIFMA
told Labor in its recent comment as part of department's request for information "it's not just exemptions that need to change" but also parts of the rule itself.
Instead, VRDP dividends will be set at a fixed spread to the Securities Industry and Financial Markets Association Municipal Swap Index (SIFMA
Waughs industry positions have included board seats with SIFMA
, The Clearing House, the Financial Services Forum and the FINRA Board of Governors.
In addition, Dolly has served as chairperson of the Securities Industry and Financial Markets Association (SIFMA
) Operations and Technology Steering Committee and has served on cross-industry committees with DTCC.
In the first few years, FSI was cited first by 80% of respondents, SIFMA
and FINRA were in the high single digits and the FPA was even mentioned by 5% of the presidents.
Ryan served as CEO of the Securities Industry and Financial Markets Association (SIFMA
) since 2009.
Doug was also Associate General Counsel for the Securities Industry Association (now SIFMA
), where he worked with securities and banking regulators to draft rules and seek interpretive relief in a number of different areas.
The Securities Industry and Financial Markets Association (SIFMA
) is a non-profit industry association that represents participants in the global financial services markets.
Lombard argued that SIFMA
believes the "right answer for investors is a consistent best interest standard that could apply across all types of accounts, but does not have the additional onerous conditions created by the DOL rule."