SIFMA submitted comments to the Securities and Exchange Commission (SEC) regarding its proposal on recordkeeping, reporting, notification, and security count requirements for security-based swap dealers (SBSDs), major security-based swap participants (MSBSPs), and broker-dealers.

SIFMA wrote that the SEC proposal would prescribe recordkeeping or reporting requirements based on requirements in other rules that have been proposed by the SEC but have not yet been adopted, in particular requirements relating to capital, margin, and segregation for SBSDs and MSBSPs.

SIFMA has provided comments on many of these proposals and respectfully requests that the SEC consider all of those letters carefully before adopting any portion of the security-based swap regime established under Title VII of the Dodd-Frank Act.