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…
April 9, 2019
The Honorable Josh S. Gottheimer
U.S. House of Representatives
213 Cannon House Office Building
Washington, DC 20515
The Honorable Trey Hollingsworth
U.S. House of Representatives
1641 Longworth House Office Building
Washington, DC 20515
Dear Representative Gottheimer and Representative Hollingsworth:
The Securities Industry and Financial Markets Association (SIFMA)1 would like to express our support for H.R. 1876, the Senior Security Act of 2019 and we appreciate the opportunity to work with you on this important legislation. As you know, this bipartisan bill creates a Senior Investor Taskforce within the Securities and Exchange Commission charged with identifying problems senior investors encounter, including financial exploitation and cognitive decline and identifying regulatory changes that could help senior investors. The Taskforce would report to Congress every two years on key observations, best practices, and areas for improvement identified throughout its work. Additionally, the bill requires the GAO to conduct a study on the economic costs of the financial exploitation of elder investors. The lack of good, recent data on senior financial exploitation is a problem that this section would significantly aid in resolving.
The population of senior investors is rapidly increasing. By 2030, seniors aged 65+ will account for 18% of the nation’s population. Americans over the age of 50 already account for roughly 77% of financial assets in the United States. It is estimated that senior investors are being exploited out of billions of dollars a year (roughly $3 billion per year in media-reported cases alone, while only an estimated 1 in 44 cases are reported to the authorities). This cost does not even begin to consider the wide-ranging non-financial impacts and the increased reliance on government services.
Most appalling is that the great majority of exploiters of the victims are friends, neighbors or other trusted individuals. A recent New York State study found that family members and caregivers were the bad actors in about 67% of all confirmed exploitation cases, and some studies place that number even higher. SIFMA strongly supports any efforts that focus on the most immediate and most damaging dangers faced by senior investors and believes H.R. 1876 will strengthen efforts to protect these investors from those bad actors closest to them.
SIFMA appreciates the bipartisan attention paid to this important issue and urges Congress to enact this commonsense legislation.
Sincerely,
Mark Schuermann
Managing Director, Head of Federal Government and International Affairs
SIFMA
cc: The Honorable Josh Gottheimer; The Honorable Trey Hollingsworth
1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.