Additional Comments on NASAA’s Re-proposal of Revisions to its Model Rule
SIFMA provided additional comments to the North American Securities Administrators Association, Inc. (NASAA) on the re-proposal of revisions to its…
February 3, 2021
The Honorable Carl E. Heastie
Speaker of the Assembly
State of New York
LOB 932
Albany, NY 12248
RE: Letter in Opposition to Any Form of the Stock Transfer Tax
Dear Speaker Heastie:
We write in opposition to re-imposing any form of a New York State Stock Transaction Tax (STT). Such a tax would damage New York’s position as a global financial capital, resulting in shrinkage of an industry that is the largest contributor to our economy and tax base. i Our organizations represent more than 544,000 workers in the financial services industry in New York State, those throughout the U.S., and other business groups in the state. While some see this as a tax on the securities industry itself, it is actually a tax on working families saving for retirement and college, pension funds that secure retirement for millions, as well as many individual investors, foundations and endowments.
New York State eliminated collection of a STT in 1981 ii, in response to market globalization and significant technological changes affecting market transactions. During these unprecedented and critical times, a STT targeted at the financial markets will impair New York State’s economy, adversely impact the state’s business environment, and increase the cost of investing for everyday savers and investors. In 2003, when restoration of the tax was proposed, the NYC Independent Budget Office found that reinstating the tax at half the prior rate would increase transaction costs by 23%, eliminate nearly 60,000 private sector jobs, and reduce trading volume by 18%. iii