The Derivatives Products Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on a National Association of Securities Dealers (NASD) proposed change relating to position limits and position reporting obligations for conventional index and equity funds, Release No. 34-53189; File No. SR-NASD-2006-007.  SIA’s recommendations address several issues, including: 1) the definition of covered indices; 2) the A.M.-Settlement Requirement; and 3) option position reporting levels.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.