August 16, 2022

Submitted electronically via SEC.gov
Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549

Re: Request for Comment on Certain Information Providers Acting as Investment Advisers, Release Nos. IA-6050; IC-34618; File No. S7-18-22

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association1 (“SIFMA”), jointly with its Asset Management Group2 (“SIFMA AMG”), appreciates the opportunity to provide comments to the United States Securities and Exchange Commission (the “SEC”) on the SEC’s Request for Comment on Certain Information Providers Acting as Investment Advisers (the “RFC”).3

This comment letter offers the consolidated perspectives of our buyside and sellside members, who have substantial concerns with the potential characterization and regulation of index providers, model portfolio providers and pricing services (“Information Providers”) as investment advisers.

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 one million employees, we advocate on 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.

2 SIFMA’s Asset Management Group (SIFMA AMG) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg.
3 Request for Comment on Certain Information Providers Acting as Investment Advisers, 87 Fed. Reg. 37254 (June 22, 2022) (hereinafter, “RFC”).