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The IAA has submitted supplemental comments on the SEC’s proposal to shorten the securities settlement cycle to T+1. Our supplemental letter requests that the SEC push back the T+1 settlement cycle compliance date to September 3, 2024, replace the proposed requirement of a written agreement with a requirement that investment advisers adopt policies and procedures, and that the SEC take further action to reduce disruption in the foreign exchange (FX) markets.
IAA has joined several trade organizations to request a later compliance date for T+1 securities settlement. The SEC has proposed a March 2024 compliance date – the letter requests a September 2024 compliance date to allow the industry adequate time for the transition.
The IAA urged the SEC to exclude SEC-registered investment advisers and their clients, including private funds, from the proposed definition of dealer.
The IAA and other trade associations urge the SEC to extend the comment period for a proposal that would expand the definition of dealer to capture certain advisers and private funds.
The IAA objected to FINRA’s questions on whether standards for complex products and options should apply to investment advisers because FINRA has no authority over investment advisers.
We support the SEC’s proposal to shorten the securities settlement cycle to T+1 and provide recommendations that we believe will better balance the SEC’s desire for information with operational realities of how investment advisers engage in securities trading. We also strongly encourage the SEC to not consider moving to a T+0 settlement cycle until the T+1 settlement cycle has been implemented for at least two years and the SEC has had adequate time to analyze data from all stakeholders.
The IAA joined several other groups to urge the SEC to extend the exceedingly short 30-day comment period for the securities lending reporting to 90 days. Given the scope and breadth of this proposal, we believe that a 30-day deadline is not sufficient to solicit meaningful feedback.
The IAA, together with other associations, called on the SEC to revisit an ill-fitting application to the fixed income markets of a new rule that was intended to cover over-the-counter retail equity securities markets.
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