Attach to Form 990 or 990-EZ.
Information about Schedule O (Form 990 or 990-EZ) and its instructions is at| Return Reference | Explanation |
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| Part I, Line 10 | The discrepancy in form 990, Part I, line 10 comparative information for prior year vs current year relates to interest and dividend income of $1,072,051 that was inadvertently misclassified as unrealized gains on investments on the prior year return. Part I, Line 6 The number of volunteers was derived from SIFMA committee participants per the membership data base. |
| Part III, Line 4a | CONTINUED DEVELOPMENT AND MAINTENANCE OF BEST PRACTICES THAT ARE CONDUCIVE TO EFFICIENT CONDUCT OF THE BUSINESS OF MEMBERS OF THE ORGANIZATION: CYBERSECURITY SIFMA has emerged as a leader in cybersecurity readiness, providing actionable industry standards. SIFMA established a new decision-making committee of industry participants for both the equity and fixed income markets, which will quickly convene to determine market-wide actions to take in the case of a significant cybersecurity event. Building on the National Institute of Standards and Technology (NIST) Cybersecurity Framework, we are developing cybersecurity standards for firms of all sizes; educating the industry about evolving threats; increasing participation in FS-ISAC, the industry's forum for cyber threat information sharing; and continuing to convene industry-wide business continuity planning tests and exercises. EQUITY MARKET STRUCTURE SIFMA provided credible and well-received recommendations to reform equity market structure. We have long called for a comprehensive review of equity market structure and in 2014 established a 25-member task force, representing the many diverse firms and businesses invested in this issue. Our recommendations propose to: reverse the increasing complexity of U.S. equity markets and order types; improve access to and resiliency of the equity market data system; and enhance transparency to all investors about how orders are routed and executed. PRESERVING INVESTOR CHOICE SIFMA's engagement and grassroots efforts by our members had a substantial role in preserving an investor's right to choose the product and service model that best meets their needs. SIFMA has long advocated for the U.S. Securities and Exchange Commission (SEC) to establish a uniform standard of conduct for brokers and advisors when providing personalized investment advice. AMICUS PROGRAM: THE INDUSTRY'S VOICE IN KEY LITIGATION SIFMA files amicus briefs in court cases whose outcome could materially impact the financial services industry. Briefs educate courts about established industry and market practices, and highlight important policy concerns that transcend the particular case. The amicus program focuses on cases where parties seek to expand legal theories, ease pleading standards, or tilt procedural rules in their favor. Its goal is to contribute to positive case outcomes and lasting legal precedents that help SIFMA members manage litigation risks and costs. CREATING A CONSOLIDATED AUDIT TRAIL SIFMA has long supported efforts by the U.S. Securities and Exchange Commission (SEC) to provide regulators with timely access to a more robust and effective cross-market order and execution audit trail. We believe that a centralized and comprehensive audit trail would enable the SEC and securities self regulatory organizations (SROs) to perform monitoring, enforcement and regulatory activities more effectively. PROTECTING SENIOR INVESTORS SIFMA has created an interdisciplinary working group to address emerging issues affecting senior investors, including financial exploitation and diminished cognitive capacity. The group is working to develop principles and is also collaborating with aging organizations and experts, and state and federal regulators to develop guidance and regulations. OTC DERIVATIVES SIFMA's swap dealer and asset manager derivatives committees routinely canvass the landscape of derivatives regulatory issues and market structure developments. Through our committees, SIFMA has supported the development of more transparent and safer markets for OTC derivatives in the U.S. and abroad, including advocating for rules consistent with the agreed G20 principals for the regulation of OTC derivatives. Our goal has been making derivatives markets safer and sounder, without overly onerous burdens on market participants and without impairing market liquidity. Part III, Line 4b ADVOCACY FOR ISSUES OF IMPORTANCE TO ITS MEMBERS: We are committed to ensuring America's capital markets are safe and sound, while remaining the deepest and most liquid in the world. Commodities SIFMA and four financial industry associations filed a joint comment letter, which was accompanied by a joint memorandum of law, drafted by four law firms, and a study demonstrating the importance of bank involvement in commodities markets Consolidated Audit Trail (CAT) SIFMA remains actively engaged with the SROs, FINRA, the SEC and our members following the release of our comprehensive white paper detailing industry recommendations for the creation of the CAT; this complex regulatory system will link quotes and orders to the originating customer, and it is critical that it is implemented in a cost effective manner, with meaningful industry engagement Cybersecurity SIFMA established a new decision-making committee of industry participants for both the equity and bond markets and is identifying cybersecurity standards for firms of all sizes and capabilities Free Trade Agreements SIFMA continues to advocate that a TTIP between the U.S. and EU must include a framework in which to discuss financial services regulation to realize its full economic potential; the TPP negotiations and a prospective Bilateral Investment Treaty with China offer further promise for the U.S. economy Eminent Domain SIFMA continues to mobilize efforts on a local level to ensure municipalities understand that eminent domain stands to hurt the investors and the borrowers it seeks to help, and that there are better alternatives to repairing housing markets Equity Market Structure SIFMA established a 25-member task force that presented comprehensive recommendations to improve U.S. equity market structure Fiduciary Standard SIFMA has long advocated for the SEC to establish a uniform fiduciary standard for brokers and advisors when providing personalized investment advice Foreign Account Tax Compliance Act (FATCA) SIFMA is working with our members to implement FATCA under the new transition period which will allow financial institutions to comply more effectively while minimizing unnecessary cost burdens and reducing potential harm to the U.S. economy Money Market Fund Reform As SIFMA members prepare to comply with and operationalize the new rules, various SIFMA committees are working with the SEC on a list of FAQs to help clarify the application of the new rules and on implementing new compliance and operations requirements Best Execution of Transactions in Municipal Securities Many of SIFMA's suggestions were incorporated into the MSRB's rule proposal; SIFMA will work with the MSRB to develop guidance that assists member firms to comply with the final rule Municipal Advisor Rule SIFMA issued model documents to assist members in complying with the final rules; SIFMA also successfully advocated for a six month delay that allowed the SEC to develop two compliance FAQs and for members to adequately implement compliance programs Non-Bank Systemic Designation SIFMA has engaged with FSOC, FSB and IOSCO to advocate for an improved, more transparent and collaborative process for determining systemic designations; SIFMA does not believe that asset managers pose a threat to financial stability - SIFMA has encouraged regulators to focus on activities, as effective regulation of systemic risk is best achieved through a broad activities-based approach rather than through disparate treatment of individual entities OTC Derivatives SIFMA continues to work with members and regulators on the implementation of the CFTC's rule set and in anticipation of the SEC's rules being finalized and implemented in the coming year; major outstanding issues include the cross-border application of derivatives regulation, U.S. implementation of globally agreed standards on margin for non-centrally cleared derivatives and ongoing implementation of SEF trading Securitization Market Reform SIFMA continues to work with regulators and members to implement Reg AB2 and Risk Retention, including on issues such as privacy implications of loan level disclosure requirements Senior Investors SIFMA created a working group to facilitate the exchange of ideas and development of principles when dealing with elderly clients; the group is in dialogue with regulators to collaboratively address this emerging issue Shortened Settlement Cycle Shortening the settlement cycle on a timeframe that is workable for all market participants can benefit investors by reducing risk; SIFMA is actively working to ensure our members' voice is heard throughout this process and is serving as co-lead of an industry task force State Run Retirement Plans State-run retirement plans burden already fiscally-strained states with programs that are already available in private markets, create conflicts between federal and state laws, and have a number of implications under ERISA and the Internal Revenue Code; SIFMA is committed to addressing the country's savings challenge through financial literacy, general investment ed |
| Part III, Line 4c | SIFMA events bring together capital and financial market professionals to hear from industry leaders and policymakers on the most pressing issues facing their businesses. Conferences and events present substantive programs on key topics and a valuable networking experience. Exhibitions align member firms with solution and service providers that offer relevant resources. In 2014, SIFMA delivered more than 60 conferences and events as well as countless roundtables and workshops, providing thought leadership, critical industry and policy analysis, continuing education and professional development. Among the larger events: 2014 SIFMA ANNUAL MEETING Leaders of the financial services industry from across the country gathered in New York City for the industry's annual meeting with prominent policy makers and thought leaders. In one-on-one conversations, industry executives, regulators and visionaries shared their perspectives on how the capital markets will best serve tomorrow's economy. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR SIFMA's marquee event for more than 1,700 compliance and legal professionals hosted over 300 speakers sharing insights and trends across 65 substantive panels on the latest regulatory developments, compliance effectiveness and top industry topics. This tightly knit Society also meets regularly throughout the year at regional conferences and monthly luncheons. PRIVATE CLIENT CONFERENCE SIFMA's Private Client Conference convened over 300 leading wealth management professionals to address tactical ways to deal with the most pressing issues facing the industry, including working with millennials and other emerging investor classes, business succession planning and building trusted relationships with clients so they can best achieve their financial goals. OPERATIONS CONFERENCE & EXHIBITION SIFMA's 41st Annual Operations Conference & Exhibition convened distinguished speakers, industry experts, regulators and senior operations professionals to examine the most pressing issues impacting our industry, including a Shortened Settlement Cycle, Cybersecurity, Money Market Reform and a Consolidated Audit Trail (CAT). With firms addressing the challenges of a rapidly evolving environment, participants shared perspectives and insights into the reforms and next steps needed for operational resiliency in the financial markets. THE SECURITIES INDUSTRY INSTITUTE The Securities Industry Institute (SII) is the premier executive development program for financial services professionals. For more than 60 years, SIFMA and The Wharton School of The University of Pennsylvania have partnered to develop the industry's high-potential, rising leaders and equip participants with practical information, ideas and answers directly applicable to their present and future responsibilities. Held on the Wharton campus, participants meet for one week each March to complete required coursework for this three-consecutive year program that utilizes unique and unconventional teaching models. |
| Part III, Line 4d | Continued serving as a source of market information, including statistics on many facets of the market place and publishing research reports, trade newsletters and other periodicals and books. |
| PART VI, Line 6 | SIFMA is a membership organization with the following classes of membership: Broker-Dealer Members and Asset Manager Members. Each Broker-Dealer Member and Asset Manager Member shall be entitled to vote with respect to the election of Directors and other matters as may be submitted at any annual or other meeting of Members entitled to vote. Associate Members Associate Members shall not be entitled to vote with respect to the election of Directors and other matters as may be submitted at any annual or other meeting of Members entitled to vote, and shall not be eligible to serve as Directors of the Association. |
| PART VI, SECTION A, Line 11a | 990 REVIEW PROCESS The Accounting department of the Organization prepares the Form 990 based on audited financial information. The draft Form 990 is then reviewed by management and an external independent accounting firm. The Audit and Finance Committee will review the final draft signed off by the external independent tax accountant. This review will be noted as an agenda item at an Audit and Finance Committee meeting and will be duly noted in the minutes. The Form 990 will be provided to all voting members of the Board of Trustees prior to submission to the IRS. |
| PART VI, SECTION B, Line 12c | CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT Any employee in a position where his or her objectivity may be questioned because of an individual interest or family or personal relationship is required to notify the General Counsel. Similarly, any employee aware of any transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest is required to discuss the matter promptly with the General Counsel. In addition, once every year directors, officers, key employees, and all the employees of SIFMA are required to review a copy of the Conflict of Interest Policy and to acknowledge in writing that he or she is compliant. |
| PART VI, SECTION b, Line 15 | PROCESS FOR DETERMINING COMPENSATION The executive committee and the board acting as compensation committee hires consultants to review comparable packages for any new incoming ceo and officers. The consultant presents data for comparable positions both locally and nationally and the board's executive committee makes the final decision for the salary package. Currently, the ceo has an employment contract which was approved by the executive committee and the board, governing annual salary increase and any bonus payments. For the remaining senior officers, the annual salary increase and bonus payments are determined by the annual evaluation process which must be approved by the board's compensation committee. |
| Part VI, Section C, Line 19 | any request for governing documents, conflict of interest policy, and financial statements will be provided upon request at management's discretion. |
| Part XI, LIne 9 | Post-retirement related changes other than net periodic post retirement benefit cost $1,336,339 membership dues reserve $64,013 Transfer out (societies) $2,709 ------------ Total other changes: $1,403,061 |
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