Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
| Return Reference | Explanation |
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| PART 1, LINE 6 | VOLUNTEERS THE NUMBER OF VOLUNTEERS WAS DERIVED FROM SIFMA COMMITTEE PARTICIPANTS PER THE MEMBERSHIP DATABASE. |
| PART III, LINE 1 | MISSION (CONTINUED) SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. Our principal role is to advocate on behalf of our members interests before policymakers, regulators, the media and the public. Our primary focus is on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. SIFMA also serves 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. |
| PART III, LINE 4A | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS: PROGRAM SERVICES CONTINUED CYBERSECURITY Cybersecurity is a top priority in the financial industry to ensure the security of customer assets and information and the efficient, reliable execution of transactions within markets. It is a shared objective that demands an integrated approach but is often complicated with an overlapping patchwork of regulation. In fact, no fewer than 11 federal agencies impose some form of cybersecurity requirements. This is in addition to individual state, SRO and jurisdictional requirements, as well as standards from the National Institute of Standards and Technology (NIST) and International Organization for Standardization (ISO). As a global industry, all market participants are interconnected and part of the same ecosystem and need to work together to protect the sector as a whole. An effective and efficient cybersecurity policy is achieved most easily through harmonized, risk-based global standards that leverage extensive investments already made. The financial industry is committed to furthering the development of industry-wide cybersecurity initiatives that protect our clients and critical business infrastructure, improve data sharing between public and private entities and safeguard customer information. SIFMA is actively engaged in coordinating the effort to support a safe, secure information infrastructure, with cybersecurity resources which provide security of customer information and efficient, reliable execution of transactions. PERSONAL DATA AGGREGATION Clients have the ability to aggregate personal financial information on third-party platforms to assess their financial position. This data aggregation creates valuable opportunities for clients but also has the potential to put their data at risk if it is misused, mishandled or misappropriated. An individuals personal information is invaluable, and its protection is of paramount importance. The financial industry is committed to ensuring the safety of the clients we serve at every turn. SIFMA is coordinating a broad-based industry effort to protect a customers financial information, with a focus on investors right to securely access their own data. We have created a set of industry-wide Principles for protecting, sharing and aggregating customer financial information. SIFMA has also introduced consumer resources for our members to help consumers better protect their data and discuss this important issue with their clients and is a founding member and serves on the Board of the Financial Data Exchange (FDX). CONSOLIDATED AUDIT TRAIL (CAT) The SEC and the SROs continue to develop a comprehensive Consolidated Audit Trail (CAT) that would enable regulators to efficiently and accurately track all activity throughout the U.S. for equities and options trades. The CAT will allow regulators to link every order through its entire life cycle, including cancellations, modifications and executions, and the CAT database will link all orders with the account holder. As such, the CAT will enable regulators to conduct cross-market surveillance and market reconstruction by pulling together detailed trading data from all market centers. SROs began reporting data to the CAT in November 2018; they will develop analytic capabilities for CAT data in early 2019. Large broker-dealers are scheduled to begin reporting in November 2019 and remaining market participants in November 2020. SIFMA has focused on concerns around risks related to the collection of Personally Identifiable Information (PII). SIFMA has engaged the SEC and the SROs for adjustments to the CAT to ensure adequate data protection and response, as well as restricting access to any submitted data to a strictly controlled environment. BEST INTEREST STANDARD SIFMA strongly supports enhancing investor protections by establishing a heightened and more stringent broker-dealer best interest standard. The SEC should establish such a best interest of the customer standard through its rulemaking authority under the Securities Exchange Act of 1934. Regulation Best Interest does just that. Reg BI a decade in the making is a key development for retail brokerages and the clients they serve because it clearly and significantly raises the regulatory bar. Reg BI would require broker-dealers to act in the best interest of their retail customers when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. This new standard would apply across all brokerage accounts, would preserve a clients right to choose, and would effectively bring regulation up-to-date to where the industry is already operating. The SEC proposal also included two additional components, a proposed Form Customer Relationship Summary (Form CRS), and an interpretation regarding the standard of conduct for investment advisers. Notwithstanding SIFMAs general support, SIFMA has recommended that various aspects of Reg BI, as well as the other two component proposals, should be modified and/or clarified in order to allow firms to implement the regulation in a manner that would most effectively benefit investors. Protecting Senior Investors It is vital that we are able to protect our senior investors from financial exploitation and the dangers of cognitive decline. SIFMA has been working with industry members, academics, and state and federal lawmakers to advance policies, practices, rules, regulations and statutes which enhance senior investor protections. A growing number of states have enacted senior investor protection laws that extend to broker-dealers, and several others are currently working to develop a similar path. Additionally, FINRA Rule 2165, permitting pauses on certain suspicious activity, and FINRA Rule 4512, requiring firms to request trusted contact information from certain clients, went into effect in February 2018. SIFMA continues to push for updated laws and regulations to get ahead of this emerging threat and better equip advisors - through regional workshops, toolkits and more - to protect their aging client base. This is an issue of increasing importance, and SIFMA looks to continue to lead on this issue, as it has for the past several years. Fixing the Broken Fee Structure for Market Data Market data is the information on quotations and trades in each of the thousands of securities traded daily in U.S. financial markets. High-quality and reliable market data products are essential to enable all investors to make informed investment decisions. The SEC's Regulations NMS requires exchanges to provide quote and trade information to Securities Information Processors (SIPs), which distribute the public feed of "top-of-book" market data. In addition, Regulation NMS allows exchanges to sell proprietary products, which provide "depth-of-book" market data. Each exchange is a monopoly source of its own depth-of-book data, and broker-dealers rely on that complete set of market data to achieve best execution for their customers. SIFMA has long argued that the exchanges charge excessive fees for both top-of-book and depth-of-book market data. These excessive fees lead to unnecessary trading costs for all investors. In October 2018, the SEC agreed with SIFMA, unanimously ruling against two exchanges and finding that the exchanges had not adequately justified their price increases. SIFMA will continue to push for reform of this broken system, including changes to the market data monopoly advantage that exchanges enjoy under Regulation NMS. |
| PART III, LINE 4B | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS: PROGRAM SERVICES CONTINUED ADVOCACY SIFMA, ON BEHALF OF THE FINANCIAL SERVICES INDUSTRY, ENGAGES WITH POLICYMAKERS AND REGULATORS ON A STATE, FEDERAL AND GLOBAL LEVEL THROUGH COMMENT LETTERS, TESTIMONY, STUDIES AND MORE. SIFMAS GOAL IS TO ENSURE REGULATION IS EFFECTIVE, BALANCED AND CONSISTENT WITH ITS INTENDED PURPOSE, APPROPRIATELY COORDINATED WITH OTHER REGULATORS AND REGULATORY REGIMES, AND AVOIDS CONSTRAINING CAPITAL FORMATION AND CREDIT AVAILABILITY, OR OTHERWISE IMPEDING THE FUNCTIONING OF THE MARKETS AND THE INDIVIDUALS THEY SERVE. INTERNATIONAL ISSUES Financial services are crucial to U.S. economic prosperity, helping fuel economic activity across all industries, including manufacturing, agriculture and technology. SIFMA believes free- and fair-trade agreements promote U.S. economic growth and job creation by expanding opportunities for financial services firms to compete in overseas markets and better serve their clients. The U.S. relationship with China, the U.K. and the EU are some of the most important in the world. SIFMA continues to advocate for a level playing field between domestic and foreign financial services firms in China and supports efforts to strengthen the U.S.-China economic relationship through the U.S.-China Comprehensive Economic Dialogue. In Europe, Brexit has potentially huge implications for the financial services industry, and will fundamentally transform the U.S. relationship with U.K. and EU. With just two years until the prospective transition period ends (conditional on the two sides agreeing on the terms of separation), we continue to coordinate closely with our colleagues at the Association for Financial Markets in Europe (AFME) and Global Financial Markets Association (GFMA) to help the U.K. and EU deliver Brexit in a way that protects global financial stability. In the western hemisphere, SIFMA welcomed the news that the United States, Canada and Mexico reached agreement on a trilateral trade and investment deal to succeed NAFTA. For the first time ever in a trade and investment agreement, provisions prohibiting data localization and improving the free flow of data across borders, which are so important to many of our members businesses, is protected. SIFMA is also engaged in the financial services aspects of prospective bilateral trade and investment agreements between the U.S. and the U.K., EU and Japan. |
| PART III, LINE 4C | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS: PROGRAM SERVICES CONTINUED SIFMA ANNUAL MEETING Each fall, SIFMAs Annual Meeting gathers the most influential voices shaping todays capital markets. Through candid one-on-one conversations, expert panel discussions and in-depth breakout sessions, we assess challenges and gain insights into opportunities ahead. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR SIFMAs C&L Annual Seminar is the premier event for compliance and legal professionals working in the financial services industry. This seminar provides a unique opportunity for industry leaders and regulators to gather for three days of information sharing, networking and collaboration. With noted keynote speakers and 60+ in-depth breakout sessions, participants earn CLE credit while discussing the latest industry developments and collaborating on best practices. OPERATIONS CONFERENCE & EXHIBITION SIFMAs annual Operations Conference & Exhibition gathers operations, technology and regulatory leaders from across the securities industry for three days of collaboration, addressing key priorities and challenges. With the industry continuing to evolve in response to policy, risk, technology and regulatory changes, Ops delves into the dynamic and complex environment that is reshaping operations, the customer experience and market requirements. THE SECURITIES INDUSTRY INSTITUTE The Securities Industry Institute (SII) is the premier executive development program for financial industry professionals, hosted by SIFMA and Wharton. For 69 years, SIFMA and The Wharton School at the University of Pennsylvania have partnered to develop the industrys high-potential, rising leaders. Each March, SII brings together 800 participants from across the industry with a world-class faculty on the campus of The Wharton School in Philadelphia. Participants meet for one week over three consecutive years to develop leadership and managerial skills, and enhance investment and industry knowledge. SIIs cost-effective talent development approach delivers actionable knowledge that is implementable today: the mission of the Institute is to equip each participant with practical information, ideas, and answers directly applicable to their present and future responsibilities. Its customized curriculum is redesigned each year to reflect the needs of an ever-changing industry landscape. |
| PART III, LINE 4D | STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS: OTHER PROGRAM SERVICES 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, SECTION A, LINE 6 | MEMBERS 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 B, LINE 11A | FORM 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 HIRE 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 | AVAILABILITY OF DOCUMENTS 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 | RECONCILIATION OF NET ASSETS POSTRETIREMENT-RELATED CHANGES OTHER THAN NET PERIODIC POSTRETIREMENT BENEFIT COST ($713,150) OTHER NONOPERATING EXPENSE $48,473 MEMBERSHIP DUES RESERVE $1,250 ---------- TOTAL OTHER CHANGES: ($663,427) ========== |
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