Regulatory Comment Letters

Securities and Exchange Commission (SEC)

• Capital, Margin, and Segregation Requirements for Dodd-Frank Title VII Entities, February 22, 2013
• Letter to DOJ and SEC regarding FCPA Guidance, February 19, 2013
• Comment Period Extension Request: Capital, Margin and Segregation Standards for Title VII Entities, January 2, 2013
• General Solicitations and Advertising Under the JOBS Act, October 5, 2012
• Effective Date of New Eligible Contract Participant Definition, July 13, 2012
• Target Date Retirement Funds, May 21, 2012
• Comments on Identity Theft Red Flags, May 2, 2012
• Financial Literacy of Investors Study, March 23, 2012
• Volcker Rule Supplemental Letter--Covered Funds Issues, March 9, 2012
• Financial Instruments Reporting and Convergence Alliance letter on corporate governance and audit standard, February 23, 2012
• Financial Instruments Reporting and Convergence Alliance letter on the Public Company Accounting Oversight Board, February 23, 2012
• Request for FCPA Guidance, February 21, 2012
• Volcker Rule--Proprietary Trading Issues, February 13, 2012
• Volcker Rule--Covered Funds Issues, February 13, 2012
• Volcker Rule--Securitization Issues, February 13, 2012
• Prohibition of Conflict of Interests in ABS Transactions, February 13, 2012
• Volcker Rule--Insurance Related Issues, February 3, 2012
• Treatment of Security-Based Swaps , January 31, 2012
• Implementation of Section 953(b) of the Dodd-Frank Act, January 19, 2012
• Volcker Rule Comment Period Extension Request, November 30, 2011
• De Minimis & IDI Exemption Supplemental Letter, October 17, 2011
• Joint-Trade Comment on Stable Value Contracts Study, September 27, 2011
• Comment on Study of Random Assignment of Credit Ratings (Franken Amendment), September 13, 2011
• Joint Trade Letter on the Treatment of Inter-Affiliate Swaps, September 8, 2011
• Comments on Nationally Registered Credit Rating Agencies (NRSROs), August 8, 2011
• Credit Risk Retention Transmittal Letter, August 1, 2011
• Comments on Credit Risk Retention under Section 941 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, August 1, 2011
• Joint Commercial and Multifamily Real Estate Group Letter on Credit Risk Retention , August 1, 2011
• Risk Retention Requirements, Mortgage Related Securities , July 29, 2011
• Definition of Swap and Security-Based Swap Under Title VII, July 22, 2011
• President’s Working Group Report on Money Market Fund Reform, June 30, 2011
• Financial Services Roundtable Efforts to Educate Investors, June 22, 2011
• Volker Rule Preproposal Letter, June 14, 2011
• Joint Trade Letter, Request for Exemption from Self Effective Provisions of Title VII, June 10, 2011
• Joint Trade Letter, Request for Reproposal of Title VII Rules, May 31, 2011
• Incentive-Based Compensation Joint Agency Rulemaking, May 31, 2011
• Joint Trade Letter on Regulation MC, Ownership Limitations for Clearing Agencies and SB SEFs , April 29, 2011
• Principles Regarding Security-Based Swap Execution Facilities, April 4, 2011
• SEC Form S-3 Eligibility, References to Credit Rating Agencies, March 28, 2011
• Title VII Definitions Comment Letter, February 22, 2011
• Municipal Advisors Registration Comment Letter, February 22, 2011
• Comment on President’s Working Group Money Market Fund Report, February 11, 2011
• Comment on SEC Credit Rating Standardization Study, February 7, 2011
• Joint Trade Comments on Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges, January 11, 2011
• SEC Proposed Whistleblower Program Comment Letter, December 17, 2010
• Letter on Regulatory Process and Phase-In, December 7, 2010
• Non-Binding Shareholder Vote on Frequency of Executive Pay Proxy Vote (“Say on When”), November 18, 2010
• Non-Binding Shareholder Proxy Vote on Executive Pay (“Say on Pay”), disclosure of Golden Parachute Transactions, November 17, 2010
• Letter, Re: Dodd-Frank Sections 932, 945, November 15, 2010
• 12b-1 Fee Reform; Mutual Fund Distribution Fees; Confirmations (2010), November 5, 2010
• Key Definitions in Title VII of the Dodd-Frank Act, September 20, 2010
• The Financial Services Roundtable Submits Comments in Response to SEC Study on Standards of Care for Investment Advisers and Broker-Dealers, August 30, 2010
• The Financial Services Roundtable, together with the Housing Policy Council, appreciates this opportunity to comment on the Securities Exchange Commission’s Notice of Proposed Rulemaking to Increase Investor Protections in Asset-Backed Securities, August 22, 2010
• Joint Trade Letter Opposing Restoring American Financial Stability Act, April 8, 2010
• Joint Trade Letter on Importance of Accounting Policy, January 25, 2010
• Roundtable Sends Letter to Senate Judiciary Opposing S. 1551, “Liability for Aiding and Abetting Securities Violations Act of 2009”, September 17, 2009
• Roundtable Files Comments to the SEC on Proxy Access, August 14, 2009
• Roundtable & BITS Files Comments on SEC Proposal for Model Privacy Form, May 19, 2009
• Roundtable Files Comments to SEC on Credit Rating Agencies, March 26, 2009
• Letter to the SEC for its Study on Fair Value Accounting, as required under the Emergency Economic Stabilization Act, November 13, 2008
• Roundtable Urges SEC to Issue Guidance on Fair Value Accounting in Illiquid Markets, September 25, 2008
• Roundtable Joins Other Trades in Letter to President on Expansion of President’s Working Group September 15, 2008
• Roundtable files Comments on SEC’s Proposal on NRSROs, July 25, 2008
• Roundtable Sends Letter to SEC on its Emergency Order on Naked Short Selling, July 18, 2008
• Roundtable files Comments with SEC for Record of Fair Value Accounting Roundtable, July 8, 2008
• Roundtable and BITS file comment letter on Proposed Amendments to Regulation S-P, May 12, 2008
• Roundtable Files Comments to SEC on its Proposed Mutual Fund Prospectus Summary, February 28, 2008