TY 2019 Form 990

(A) Name and title	(B) Average hours per week (list any hours for related organizations below dotted line)	(C) Position (do not check more than one box, unless person is both an officer and a director/trustee)	(E) Reportable compensation from related organizations (W-2/1099-MISC)	(F) Estimated amount of other compensation from the organization and related organizations
(1) KENNETH E BENTSEN JR...................................................................... PRESIDENT & CEO	40.00 ................. 0.00	X	X			2,464,388	81,132
(2) JOSEPH SEIDEL...................................................................... COO	40.00 ................. 0.00			X		1,088,184	63,322
(3) IRA D HAMMERMAN...................................................................... EVP/GC (SEE SCH. J 457 FN)	40.00 ................. 0.00		X			985,828	77,952
(4) DAVID B KRASNER...................................................................... CFO & CAO	40.00 ................. 0.00		X			691,264	79,145
(5) TIMOTHY W CAMERON...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00				X	617,111	68,972
(6) CHERYL L CRISPEN...................................................................... EXECUTIVE PRESIDENT	40.00 ................. 0.00			X		590,860	40,915
(7) JAMIE WALL...................................................................... EXECUTIVE VICE PRESIDENT	40.00 ................. 0.00			X		564,156	12,267
(8) VICTORIA CUMINGS...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00				X	518,651	50,493
(9) ROBERT TOOMEY...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00				X	485,901	80,347
(10) CARTER K MCDOWELL...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00				X	493,461	69,104
(11) MARK SCHUERMANN...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00				X	524,837	24,835
(12) SALVATORE CHIARELLI...................................................................... EXECUTIVE VICE PRESIDENT	40.00 ................. 0.00			X		373,132	65,973
(13) JOSEPH E SWEENEY...................................................................... CHAIRMAN OF THE BOARD	2.00 ................. 0.00	X	X			0	0
(14) JOHN FW ROGERS...................................................................... CHAIR ELECT	1.00 ................. 0.00	X	X			0	0
(15) THOMAS PLUTA...................................................................... VICE CHAIR	1.00 ................. 0.00	X	X			0	0
(16) JAMES WALLIN...................................................................... TREASURER	2.00 ................. 0.00	X	X			0	0
(17) JAMES ALLEN...................................................................... DIRECTOR	1.00 ................. 0.00	X				0	0

(A) Name and title	(B) Average hours per week (list any hours for related organizations below dotted line)	(C) Position (do not check more than one box, unless person is both an officer and a director/trustee)
(18) KEVIN BAILEY........................................................................ DIRECTOR	1.00 .......................0.00	X
(19) VALERIE BROWN........................................................................ DIRECTOR	1.00 .......................0.00	X
(20) KENNETH CELLA........................................................................ DIRECTOR	1.00 .......................0.00	X
(21) LAURA CHEPUCAVAGE........................................................................ DIRECTOR (AS OF 11/2019)	1.00 .......................0.00	X
(22) MICHAEL CROWL........................................................................ DIRECTOR	1.00 .......................0.00	X
(23) JAMES CROWLEY........................................................................ DIRECTOR	1.00 .......................0.00	X
(24) MICHAEL DURBIN........................................................................ DIRECTOR	1.00 .......................0.00	X
(25) MATTHEW ENYEDI........................................................................ DIRECTOR	1.00 .......................0.00	X
(26) JOHN ETTELSON........................................................................ DIRECTOR	1.00 .......................0.00	X
(27) PAUL GALIETTO........................................................................ DIRECTOR	1.00 .......................0.00	X
(28) ROBERT HAWLEY........................................................................ DIRECTOR	1.00 .......................0.00	X
(29) LISA KIDD HUNT........................................................................ DIRECTOR	1.00 .......................0.00	X
(30) SPYRO KARETSOS........................................................................ DIRECTOR	1.00 .......................0.00	X
(31) JAMES KELLIGREW JR........................................................................ DIRECTOR	1.00 .......................0.00	X
(32) FRANCIS KELLY........................................................................ DIRECTOR	1.00 .......................0.00	X
(33) LESLEY KELLY........................................................................ DIRECTOR (AS OF 01/2020)	1.00 .......................0.00	X
(34) JIM KERR........................................................................ DIRECTOR	1.00 .......................0.00	X
(35) MICHAEL KISBER........................................................................ DIRECTOR (AS OF 11/2019)	1.00 .......................0.00	X
(36) ANDREW KOMAROFF........................................................................ DIRECTOR	1.00 .......................0.00	X
(37) RONALD KRUSZEWSKI........................................................................ DIRECTOR	1.00 .......................0.00	X
(38) THOMAS MCDONALD........................................................................ DIRECTOR	1.00 .......................0.00	X
(39) CHARLOTTE MCLAUGHLIN........................................................................ DIRECTOR	1.00 .......................0.00	X
(40) THOMAS MERCHANT........................................................................ DIRECTOR	1.00 .......................0.00	X
(41) CRAIG MESSINGER........................................................................ DIRECTOR	1.00 .......................0.00	X
(42) BRAND MEYER........................................................................ DIRECTOR	1.00 .......................0.00	X
(43) SHELLEY O'CONNOR........................................................................ DIRECTOR	1.00 .......................0.00	X
(44) DOUGLAS PREISER........................................................................ DIRECTOR	1.00 .......................0.00	X
(45) BRENDAN REILLY........................................................................ DIRECTOR	1.00 .......................0.00	X
(46) PAUL REILLY........................................................................ DIRECTOR	1.00 .......................0.00	X
(47) JIM REYNOLDS........................................................................ DIRECTOR	1.00 .......................0.00	X
(48) JEFFREY ROSEN........................................................................ DIRECTOR	1.00 .......................0.00	X
(49) PETER SCHNEIDER........................................................................ DIRECTOR	1.00 .......................0.00	X
(50) DEB SCHONEMAN........................................................................ DIRECTOR (AS OF 11/2019)	1.00 .......................0.00	X
(51) MARK STEFFENSEN........................................................................ DIRECTOR	1.00 .......................0.00	X
(52) KASHIF ZAFAR........................................................................ DIRECTOR (AS OF 11/2019)	1.00 .......................0.00	X
(53) JOHN TAFT........................................................................ DIRECTOR (THRU 11/2019)	1.00 .......................0.00	X
(54) LISA DOLLY........................................................................ DIRECTOR (THRU 11/2019)	1.00 .......................0.00	X
(55) TIM HOCKEY........................................................................ DIRECTOR (THRU 11/2019)	1.00 .......................0.00	X
(56) GENE KIM........................................................................ DIRECTOR (THRU 11/2019)	1.00 .......................0.00	X

(A) Name and business address	(B) Description of services	(C) Compensation
PAUL WEISS RIFKIND WHARTON & GARRISON 1285 AVENUE OF THE AMERICAS NEW YORK,NY100196064	LEGAL	705,000
CLEARY GOTTLIEB STEEN & HAMILTON LLP 2000 PENNSYLVANIA AVENUE NW WASHINGTON,DC200061801	LEGAL	640,422
ERNST & YOUNG LLP PO BOX 640382 PITTSBURGH,PA152640382	CONSULTING	627,482
DAVIS POLK & WARDWELL LLP 901 15TH STREET NW WASHINGTON,DC20005	LEGAL	566,558
SIDLEY AUSTIN LLP 1 S DEARBORN FLOOR 12 CHICAGO,IL60603	LEGAL	198,986
2 Total number of independent contractors (including but not limited to those listed above) who received more than $100,000 of compensation from the organization 14

- TIN:

SCHEDULE C
(Form 990 or 990-EZ)

Department of the Treasury
Internal Revenue Service

Political Campaign and Lobbying Activities

For Organizations Exempt From Income Tax Under section 501(c) and section 527

SchCMd Bullet

Complete if the organization is described below. SchCMd Bullet

Attach to Form 990 or Form 990-EZ.
SchCMd Bullet

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

2019

Open to Public
Inspection

If the organization answered "Yes" on Form 990, Part IV, Line 3, or Form 990-EZ, Part V, line 46 (Political Campaign Activities), then
Round Bullet

Section 501(c)(3) organizations: Complete Parts I-A and B. Do not complete Part I-C.
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Section 501(c) (other than section 501(c)(3)) organizations: Complete Parts I-A and C below. Do not complete Part I-B.
Round Bullet

Section 527 organizations: Complete Part I-A only.
If the organization answered "Yes" on Form 990, Part IV, Line 4, or Form 990-EZ, Part VI, line 47 (Lobbying Activities), then
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Section 501(c)(3) organizations that have filed Form 5768 (election under section 501(h)): Complete Part II-A. Do not complete Part II-B.
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Section 501(c)(3) organizations that have NOT filed Form 5768 (election under section 501(h)): Complete Part II-B. Do not complete Part II-A.
If the organization answered "Yes" on Form 990, Part IV, Line 5 (Proxy Tax) (see separate instructions) or Form 990-EZ, Part V, line 35c (Proxy Tax) (see separate instructions), then
Round Bullet

Section 501(c)(4), (5), or (6) organizations: Complete Part III.

Name of the organization

SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION

Employer identification number

32-0178959

Part I-A

Complete if the organization is exempt under section 501(c) or is a section 527 organization.

Provide a description of the organization’s direct and indirect political campaign activities in Part IV (see instructions for definition of “political campaign activities")

Political campaign activity expenditures (see instructions) .................................................................... SchCMd Bullet

Volunteer hours for political campaign activities (see instructions) ..................................................................

Part I-B

Complete if the organization is exempt under section 501(c)(3).

Enter the amount of any excise tax incurred by the organization under section 4955 ................................ SchCMd Bullet

Enter the amount of any excise tax incurred by organization managers under section 4955 ....................... SchCMd Bullet

If the organization incurred a section 4955 tax, did it file Form 4720 for this year? .........................................

Yes No

Was a correction made? ......................................................................................................................

Yes No

If "Yes," describe in Part IV.

Part I-C

Complete if the organization is exempt under section 501(c), except section 501(c)(3).

Enter the amount directly expended by the filing organization for section 527 exempt function activities ..... SchCMd Bullet

Enter the amount of the filing organization's funds contributed to other organizations for section 527 exempt function activities ............................................................................................................................ SchCMd Bullet

Total exempt function expenditures. Add lines 1 and 2. Enter here and on Form 1120-POL, line 17b........... SchCMd Bullet

Did the filing organization file Form 1120-POL for this year? ...................................................................

Yes No

Enter the names, addresses and employer identification number (EIN) of all section 527 political organizations to which the filing
organization made payments. For each organization listed, enter the amount paid from the filing organization’s funds. Also enter the amount of political contributions received that were promptly and directly delivered to a separate political organization, such as a separate segregated fund or a political action committee (PAC). If additional space is needed, provide information in Part IV.

(a) Name	(b) Address	(c) EIN	(d) Amount paid from filing organization's funds. If none, enter -0-.	(e) Amount of political contributions received and promptly and directly delivered to a separate political organization. If none, enter -0-.
1
2
3
4
5
6

For Paperwork Reduction Act Notice, see the instructions for Form 990 or 990-EZ.

Cat. No. 50084S

Schedule C (Form 990 or 990-EZ) 2019

Page 2

Part II-A

Complete if the organization is exempt under section 501(c)(3) and filed Form 5768 (election under section 501(h)).

A Check SchCMd Bullet

if the filing organization belongs to an affiliated group (and list in Part IV each affiliated group member's name, address, EIN, expenses, and share of excess lobbying expenditures).
B Check SchCMd Bullet

if the filing organization checked box A and "limited control" provisions apply.

Limits on Lobbying Expenditures (The term "expenditures" means amounts paid or incurred.)		(b) Affiliated group totals
1a	Total lobbying expenditures to influence public opinion (grass roots lobbying) ......................
b	Total lobbying expenditures to influence a legislative body (direct lobbying) ........................
c	Total lobbying expenditures (add lines 1a and 1b) ............................................................
d	Other exempt purpose expenditures ...............................................................................
e	Total exempt purpose expenditures (add lines 1c and 1d) ..................................................
f	Lobbying nontaxable amount. Enter the amount from the following table in both columns.
	If the amount on line 1e, column (a) or (b) is:The lobbying nontaxable amount is:
	Not over $500,00020% of the amount on line 1e.
	Over $500,000 but not over $1,000,000$100,000 plus 15% of the excess over $500,000.
	Over $1,000,000 but not over $1,500,000$175,000 plus 10% of the excess over $1,000,000.
	Over $1,500,000 but not over $17,000,000$225,000 plus 5% of the excess over $1,500,000.
	Over $17,000,000$1,000,000.

g	Grassroots nontaxable amount (enter 25% of line 1f) .................................................
h	Subtract line 1g from line 1a. If zero or less, enter -0-. ................................................
i	Subtract line 1f from line 1c. If zero or less, enter -0-. ................................................
j	If there is an amount other than zero on either line 1h or line 1i, did the organization file Form 4720 reporting section 4911 tax for this year? ...................................................................................................................	Yes No

4-Year Averaging Period Under Section 501(h) (Some organizations that made a section 501(h) election do not have to complete all of the five columns below. See the separate instructions for lines 2a through 2f.)
Lobbying Expenditures During 4-Year Averaging Period
	Calendar year (or fiscal year beginning in)	(a) 2016	(b) 2017	(c) 2018	(d) 2019	(e) Total

2a	Lobbying nontaxable amount

b	Lobbying ceiling amount (150% of line 2a, column(e))

c	Total lobbying expenditures

d	Grassroots nontaxable amount

e	Grassroots ceiling amount (150% of line 2d, column (e))

f	Grassroots lobbying expenditures

Schedule C (Form 990 or 990-EZ) 2019

Page 3

Part II-B

Complete if the organization is exempt under section 501(c)(3) and has NOT filed Form 5768 (election under section 501(h)).

For each "Yes" response on lines 1a through 1i below, provide in Part IV a detailed description of the lobbying activity.

(a)

Yes|No

(b)

Amount

During the year, did the filing organization attempt to influence foreign, national, state or local legislation, including any attempt to influence public opinion on a legislative matter or referendum, through the use of:

Volunteers? ...........................................................................................................

Paid staff or management (include compensation in expenses reported on lines 1c through 1i)? ........

Media advertisements? ...................................................................................................

Mailings to members, legislators, or the public? .............................................................................

Publications, or published or broadcast statements? ...........................................................

Grants to other organizations for lobbying purposes? ..........................................................

Direct contact with legislators, their staffs, government officials, or a legislative body? .......................

Rallies, demonstrations, seminars, conventions, speeches, lectures, or any similar means? ..................

Other activities? ...................................................................................................................

Total. Add lines 1c through 1i ....................................................................................................

Did the activities in line 1 cause the organization to be not described in section 501(c)(3)? .....

If "Yes," enter the amount of any tax incurred under section 4912 ...........................................

If "Yes," enter the amount of any tax incurred by organization managers under section 4912 ...................

If the filing organization incurred a section 4912 tax, did it file Form 4720 for this year? ........................

Part III-A

Complete if the organization is exempt under section 501(c)(4), section 501(c)(5), or section 501(c)(6).

Yes

Were substantially all (90% or more) dues received nondeductible by members? ...............................................

Did the organization make only in-house lobbying expenditures of $2,000 or less? ............................................

Did the organization agree to carry over lobbying and political expenditures from the prior year? .................................

Yes

Part III-B

Complete if the organization is exempt under section 501(c)(4), section 501(c)(5), or section 501(c)(6) and if either (a) BOTH Part III-A, lines 1 and 2, are answered "No" OR (b) Part III-A, line 3, is answered “Yes."

Dues, assessments and similar amounts from members ......................................................................

39,941,558

Section 162(e) nondeductible lobbying and political expenditures (do not include amounts of political expenses for which the section 527(f) tax was paid).

Current year .............................................................................................................................

6,640,000

Carryover from last year ............................................................................................................

1,765,885

Total ...........................................................................................................................................

8,405,885

Aggregate amount reported in section 6033(e)(1)(A) notices of nondeductible section 162(e) dues .

6,647,068

If notices were sent and the amount on line 2c exceeds the amount on line 3, what portion of the excess does the organization agree to carryover to the reasonable estimate of nondeductible lobbying and political expenditure next year? ......................................................................................................................

1,468,817

Taxable amount of lobbying and political expenditures (see instructions) .........................................

290,000

Part IV

Supplemental Information

Provide the descriptions required for Part l-A, line 1; Part l-B, line 4; Part l-C, line 5; Part II-A (affiliated group list); Part II-A, lines 1 and 2 (see instructions), and Part ll-B, line 1. Also, complete this part for any additional information.

Return Reference	Explanation

Schedule C (Form 990 or 990EZ) 2019

Additional Data

Software ID:
Software Version:

- TIN:

SCHEDULE D
(Form 990)

Department of the Treasury
Internal Revenue Service

Supplemental Financial Statements

Complete if the organization answered "Yes," on Form 990,
Part IV, line 6, 7, 8, 9, 10, 11a, 11b, 11c, 11d, 11e, 11f, 12a, or 12b.
SchDMd Bullet

Attach to Form 990.
SchDMd Bullet

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

2019

Open to Public Inspection

Name of the organization

SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION

Employer identification number

32-0178959

Part I

Organizations Maintaining Donor Advised Funds or Other Similar Funds or Accounts. Complete if the organization answered "Yes" on Form 990, Part IV, line 6.

		(a) Donor advised funds	(b) Funds and other accounts
1	Total number at end of year .........
2	Aggregate value of contributions to (during year)
3	Aggregate value of grants from (during year)
4	Aggregate value at end of year ........

Did the organization inform all donors and donor advisors in writing that the assets held in donor advised funds are the organization’s property, subject to the organization’s exclusive legal control? ............

Yes No

Did the organization inform all grantees, donors, and donor advisors in writing that grant funds can be used only for charitable purposes and not for the benefit of the donor or donor advisor, or for any other purpose conferring impermissible private benefit? ...................................

Yes No

Part II

Conservation Easements.
Complete if the organization answered "Yes" on Form 990, Part IV, line 7.

Purpose(s) of conservation easements held by the organization (check all that apply).

Preservation of land for public use (e.g., recreation or education) Preservation of an historically important land area

Protection of natural habitat Preservation of a certified historic structure

Preservation of open space

Complete lines 2a through 2d if the organization held a qualified conservation contribution in the form of a conservation easement on the last day of the tax year.


a	Total number of conservation easements ......................	2a
b	Total acreage restricted by conservation easements ....................	2b
c	Number of conservation easements on a certified historic structure included in (a) .....	2c
d	Number of conservation easements included in (c) acquired after 7/25/06, and not on a historic structure listed in the National Register ...	2d

Number of conservation easements modified, transferred, released, extinguished, or terminated by the organization during the
tax year SchDMd Bullet

Number of states where property subject to conservation easement is located SchDMd Bullet

Does the organization have a written policy regarding the periodic monitoring, inspection, handling of violations, and enforcement of the conservation easements it holds? ............

Yes No

Staff and volunteer hours devoted to monitoring, inspecting, handling of violations, and enforcing conservation easements during the year
SchDMd Bullet

Amount of expenses incurred in monitoring, inspecting, handling of violations, and enforcing conservation easements during the year
SchDMd Bullet

Does each conservation easement reported on line 2(d) above satisfy the requirements of section 170(h)(4)(B)(i) and section 170(h)(4)(B)(ii)? .............................

Yes No

In Part XIII, describe how the organization reports conservation easements in its revenue and expense statement, and
balance sheet, and include, if applicable, the text of the footnote to the organization’s financial statements that describes
the organization’s accounting for conservation easements.

Part III

Organizations Maintaining Collections of Art, Historical Treasures, or Other Similar Assets.
Complete if the organization answered "Yes" on Form 990, Part IV, line 8.

If the organization elected, as permitted under FASB ASC 958, not to report in its revenue statement and balance sheet works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of public service, provide, in Part XIII, the text of the footnote to its financial statements that describes these items.

If the organization elected, as permitted under FASB ASC 958, to report in its revenue statement and balance sheet works of art, historical treasures, or other similar assets held for public exhibition, education, or research in furtherance of public service, provide the following amounts relating to these items:

(i)

Revenue included on Form 990, Part VIII, line 1 ......................... SchDMd Bullet

(ii)

Assets included in Form 990, Part X ............................... SchDMd Bullet

If the organization received or held works of art, historical treasures, or other similar assets for financial gain, provide the
following amounts required to be reported under FASB ASC 958 relating to these items:

Revenue included on Form 990, Part VIII, line 1 .......................... SchDMd Bullet

Assets included in Form 990, Part X ............................... SchDMd Bullet

For Paperwork Reduction Act Notice, see the Instructions for Form 990.

Cat. No. 52283D

Schedule D (Form 990) 2019

Page 2

Part III

Organizations Maintaining Collections of Art, Historical Treasures, or Other Similar Assets (continued)

Using the organization’s acquisition, accession, and other records, check any of the following that are a significant use of its collection items (check all that apply):

Public exhibition

Loan or exchange programs

Scholarly research

Other

Preservation for future generations

Provide a description of the organization’s collections and explain how they further the organization’s exempt purpose in
Part XIII.

During the year, did the organization solicit or receive donations of art, historical treasures or other similar
assets to be sold to raise funds rather than to be maintained as part of the organization’s collection?...

Yes No

Part IV

Escrow and Custodial Arrangements. Complete if the organization answered "Yes" on Form 990, Part IV, line 9, or reported an amount on Form 990, Part X, line 21.

Is the organization an agent, trustee, custodian or other intermediary for contributions or other assets not
included on Form 990, Part X? ....................................

Yes No


b	If "Yes," explain the arrangement in Part XIII and complete the following table:		Amount
c	Beginning balance .............................	1c
d	Additions during the year ............................	1d
e	Distributions during the year ..........................	1e
f	Ending balance ................................	1f

Did the organization include an amount on Form 990, Part X, line 21, for escrow or custodial account liability? ...

Yes No

If "Yes," explain the arrangement in Part XIII. Check here if the explanation has been provided in Part XIII ....

Part V

Endowment Funds.
Complete if the organization answered "Yes" on Form 990, Part IV, line 10.

		(a) Current year	(b) Prior year	(c) Two years back	(d) Three years back	(e) Four years back

1a	Beginning of year balance ....
b	Contributions ...
c	Net investment earnings, gains, and losses
d	Grants or scholarships ...
e	Other expenditures for facilities and programs ...
f	Administrative expenses ....
g	End of year balance ......

Provide the estimated percentage of the current year end balance (line 1g, column (a)) held as:

Board designated or quasi-endowment SchDMd Bullet

Permanent endowment SchDMd Bullet

Term endowment SchDMd Bullet

The percentages on lines 2a, 2b, and 2c should equal 100%.

Are there endowment funds not in the possession of the organization that are held and administered for the
organization by:

Yes

(i) Unrelated organizations .................

3a(i)

(ii) Related organizations .................

3a(ii)

If "Yes" on 3a(ii), are the related organizations listed as required on Schedule R? .........

Describe in Part XIII the intended uses of the organization's endowment funds.

Part VI

Land, Buildings, and Equipment.
Complete if the organization answered "Yes" on Form 990, Part IV, line 11a. See Form 990, Part X, line 10.

Description of property		(a) Cost or other basis (investment)	(b) Cost or other basis (other)	(c) Accumulated depreciation	(d) Book value

1a	Land .....
b	Buildings ....
c	Leasehold improvements	19,074,604	15,009,400	4,065,204
d	Equipment ....	6,569,814	5,206,643	1,363,171
e	Other .....
Total. Add lines 1a through 1e. (Column (d) must equal Form 990, Part X, column (B), line 10(c).)..				5,428,375

Schedule D (Form 990) 2019

Page 3

Part VII

InvestmentsOther Securities.
Complete if the organization answered "Yes" on Form 990, Part IV, line 11b. See Form 990, Part X, line 12.

(a) Description of security or category (including name of security)	(b) Book value	(c) Method of valuation: Cost or end-of-year market value
(1) Financial derivatives.........
(2) Closely-held equity interests........
(3)Other
(B)
(C)
(D)
(E)
(F)
(G)
(H)
(I)
Total. (Column (b) must equal Form 990, Part X, col. (B) line 12.)

Part VIII

InvestmentsProgram Related. Complete if the organization answered 'Yes' on Form 990, Part IV, line 11c. See Form 990, Part X, line 13.

(a) Description of investment	(b) Book value	(c) Method of valuation: Cost or end-of-year market value

(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
Total. (Column (b) must equal Form 990, Part X, col.(B) line 13.)

Part IX

Other Assets.
Complete if the organization answered 'Yes' on Form 990, Part IV, line 11d. See Form 990, Part X, line 15.

(a) Description				(b) Book value
(1)OTHER LONG-TERM ASSETS				1,976,292
(2)DUE FROM THIRD PARTIES				1,278,303
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
Total. (Column (b) must equal Form 990, Part X, col.(B) line 15.)...........				3,254,595

Part X

Other Liabilities.
Complete if the organization answered 'Yes' on Form 990, Part IV, line 11e or 11f. See Form 990, Part X, line 25.

1.(a) Description of liability	(b) Book value
(1) Federal income taxes
(3)
(4)
(5)
(6)
(7)
(8)
(9)
Total. (Column (b) must equal Form 990, Part X, col.(B) line 25.)	11,586,600
2. Liability for uncertain tax positions. In Part XIII, provide the text of the footnote to the organization's financial statements that reports the organization's liability for uncertain tax positions under FIN 48 (ASC 740). Check here if the text of the footnote has been provided in Part XIII

Schedule D (Form 990) 2019

Page 4

Part XI Reconciliation of Revenue per Audited Financial Statements With Revenue per Return. Complete if the organization answered 'Yes' on Form 990, Part IV, line 12a.
1	Total revenue, gains, and other support per audited financial statements .......			1	46,034,662
2	Amounts included on line 1 but not on Form 990, Part VIII, line 12:
a	Net unrealized gains (losses) on investments ....	2a	635,763
b	Donated services and use of facilities .........	2b
c	Recoveries of prior year grants ...........	2c
d	Other (Describe in Part XIII.) ............	2d
e	Add lines 2a through 2d .....................			2e	635,763
3	Subtract line 2e from line 1..................			3	45,398,899
4	Amounts included on Form 990, Part VIII, line 12, but not on line 1:
a	Investment expenses not included on Form 990, Part VIII, line 7b .	4a
b	Other (Describe in Part XIII.) ...........	4b
c	Add lines 4a and 4b....................			4c	0
5	Total revenue. Add lines 3 and 4c. (This must equal Form 990, Part I, line 12.) ......			5	45,398,899

Part XII Reconciliation of Expenses per Audited Financial Statements With Expenses per Return. Complete if the organization answered 'Yes' on Form 990, Part IV, line 12a.
1	Total expenses and losses per audited financial statements ...........			1	50,247,134
2	Amounts included on line 1 but not on Form 990, Part IX, line 25:
a	Donated services and use of facilities .........	2a
b	Prior year adjustments ............	2b
c	Other losses ................	2c
d	Other (Describe in Part XIII.) ............	2d	-81,280
e	Add lines 2a through 2d....................			2e	-81,280
3	Subtract line 2e from line 1...................			3	50,328,414
4	Amounts included on Form 990, Part IX, line 25, but not on line 1:
a	Investment expenses not included on Form 990, Part VIII, line 7b ..	4a
b	Other (Describe in Part XIII.) ............	4b
c	Add lines 4a and 4b.....................			4c	0
5	Total expenses. Add lines 3 and 4c. (This must equal Form 990, Part I, line 18.) ......			5	50,328,414

Part XIII

Supplemental Information

Provide the descriptions required for Part II, lines 3, 5, and 9; Part III, lines 1a and 4; Part lV, lines 1b and 2b; Part V, line 4; Part X, line 2; Part XI, lines 2d and 4b; and Part XII, lines 2d and 4b. Also complete this part to provide any additional information.

Return Reference	Explanation
PART IV, LINE 2B:	CUSTODIAL ARRANGEMENTS IN ORDER TO FINANCE CERTAIN MEMBER DRIVEN PROJECTS THAT ARE BEYOND SIFMA'S OPERATING BUDGET RESOURCES AND WHICH IMPACT ONLY A SUBSET OF MEMBERS, SIFMA SYNDICATES OUT SUCH PROJECT COSTS TO PARTICIPATING MEMBER FIRMS. THIRD-PARTY PROJECT COSTS (AND ASSOCIATED MEMBER REIMBURSEMENTS) ARE INCLUDED IN SIFMA'S BALANCE SHEET. IN 2020, THE SYNDICATED FUNDS COLLECTED FROM MEMBERS AND DISBURSED FOR SUCH SPECIAL PROJECTS TOTALED $1,813,015 AND $2,217,383, RESPECTIVELY.
PART X, LINE 2:	FIN 48 THE ASSOCIATION FOLLOWS GUIDANCE THAT CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS GUIDANCE PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN ONLY BE RECOGNIZED IN THE FINANCIAL STATEMENTS IF THE POSITION IS "MORE-LIKELY-THAN-NOT" TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE ASSOCIATION IS EXEMPT FROM FEDERAL INCOME TAX UNDER SECTION 501(C)(6) OF THE INTERNAL REVENUE CODE, THOUGH IT IS SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. THE ASSOCIATION HAS PROCESSES PRESENTLY IN PLACE TO ENSURE THE MAINTENANCE OF ITS TAX-EXEMPT STATUS; TO IDENTIFY AND REPORT UNRELATED INCOME; TO DETERMINE ITS FILING AND TAX OBLIGATIONS IN JURISDICTIONS FOR WHICH IT HAS NEXUS; AND TO IDENTIFY AND EVALUATE OTHER MATTERS THAT MAY BE CONSIDERED TAX POSITIONS. THE ASSOCIATION HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS.
PART XII, LINE 2D - OTHER ADJUSTMENTS:	OTHER NONOPERATING EXPENSES 149,030. NET PERIODIC POST RETIREMENT BENEFIT COST -230,310.

Schedule D (Form 990) 2019

Additional Data

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Schedule I
(Form 990)

Department of the Treasury
Internal Revenue Service

Grants and Other Assistance to Organizations,
Governments and Individuals in the United States

Complete if the organization answered "Yes," on Form 990, Part IV, line 21 or 22.
lBullet

Attach to Form 990.
lBullet

Go to www.irs.gov/Form990 for the latest information.

OMB No. 1545-0047

2019

Open to Public
Inspection

Name of the organization
SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION

Employer identification number
32-0178959

Part I

General Information on Grants and Assistance

Does the organization maintain records to substantiate the amount of the grants or assistance, the grantees' eligibility for the grants or assistance, and
the selection criteria used to award the grants or assistance? ........................

Yes No

Describe in Part IV the organization's procedures for monitoring the use of grant funds in the United States.

Part II

Grants and Other Assistance to Domestic Organizations and Domestic Governments. Complete if the organization answered "Yes" on Form 990, Part IV, line 21, for any recipient

that received more than $5,000. Part II can be duplicated if additional space is needed.

(a) Name and address of organization or government	(b) EIN	(c) IRC section (if applicable)	(d) Amount of cash grant	(h) Purpose of grant or assistance
(1) CENTER FORWARD 555 12TH ST NW SUITE 700 WASHINGTON,DC20004	27-2429741	501(C)(4)	40,000	PROGRAM SUPPORT
(2) COMMITTEE ON CAPITAL MARKETS REGULATION INC 134 MOUNT AUBURN STREET CAMBRIDGE,MA02138	30-0406260	501(C)(3)	50,000	PROGRAM SUPPORT
(3) FORMER MEMBERS OF CONGRESS INC 1401 K STREET NW SUITE 503 WASHINGTON,DC20005	54-0883744	501(C)(3)	8,000	PROGRAM SUPPORT
(4) NATIONAL ADULT PROTECTION SERVICES ASSOCIATION 1612 K STREET NW 200 WASHINGTON,DC20006	30-0044497	501(C)(3)	18,000	PROGRAM SUPPORT
(5) NCSL FOUNDATION FOR STATE LEGISLATURES 7700 EAST FIRST PLACE DENVER,CO80230	74-2232576	501(C)(3)	7,500	PROGRAM SUPPORT
(6) PREVENT CANCER FOUNDATION 1600 DUKE STREET SUITE 500 ALEXANDRIA,VA22314	52-1429544	501(C)(3)	10,000	PROGRAM SUPPORT
(7) SEC HISTORICAL SOCIETY 1101 PENNSYLVANIA AVE NW NO 3 WASHINGTON,DC20004	52-2213646	501(C)(3)	10,000	PROGRAM SUPPORT
(8) UNITED STATES CAPITOL HISTORICAL SOCIETY 200 MARYLAND AVE NO 400 WASHINGTON,DC20002	52-0796820	501(C)(3)	10,000	PROGRAM SUPPORT

Enter total number of section 501(c)(3) and government organizations listed in the line 1 table ................. Bullet Image

Enter total number of other organizations listed in the line 1 table ........................ . Bullet Image

For Paperwork Reduction Act Notice, see the Instructions for Form 990.

Cat. No. 50055P

Schedule I (Form 990) 2019

Page 2

Part III

Grants and Other Assistance to Domestic Individuals. Complete if the organization answered "Yes" on Form 990, Part IV, line 22.
Part III can be duplicated if additional space is needed.

(a) Type of grant or assistance	(b) Number of recipients	(c) Amount of cash grant	(d) Amount of noncash assistance	(e) Method of valuation (book, FMV, appraisal, other)	(f) Description of noncash assistance

(1)
(2)
(3)
(4)
(5)
(6)
(7)

Part IV

Supplemental Information. Provide the information required in Part I, line 2; Part III, column (b); and any other additional information.

Return Reference	Explanation
PART I, LINE 2:	GRANT MONITORING SIFMA PROVIDES SUPPORT TO CHARITABLE ORGANIZATIONS TO HELP THOSE ORGANIZATIONS FURTHER THEIR EXEMPT PROGRAMS. SIFMA IS NOT A GRANT MAKING ORGANIZATION BUT WILL OCCASIONALLY AWARD A GRANT TO ORGANIZATIONS IN SUPPORT OF A PROJECT THAT ALIGNS ITSELF WITH SIFMA'S MISSION OF PROMOTING AND SUPPORTING A STRONG FINANCIAL INDUSTRY. SIFMA MAINTAINS IN ITS RECORDS THE ACKNOWLEDGMENT LETTER FROM THE RECIPIENT ORGANIZATION AND ANY FOLLOW UP REPORTS ON THE USE OF GRANT FUNDS.

Return Reference

Explanation

PART I, LINE 2:

GRANT MONITORING SIFMA PROVIDES SUPPORT TO CHARITABLE ORGANIZATIONS TO HELP THOSE ORGANIZATIONS FURTHER THEIR EXEMPT PROGRAMS. SIFMA IS NOT A GRANT MAKING ORGANIZATION BUT WILL OCCASIONALLY AWARD A GRANT TO ORGANIZATIONS IN SUPPORT OF A PROJECT THAT ALIGNS ITSELF WITH SIFMA'S MISSION OF PROMOTING AND SUPPORTING A STRONG FINANCIAL INDUSTRY. SIFMA MAINTAINS IN ITS RECORDS THE ACKNOWLEDGMENT LETTER FROM THE RECIPIENT ORGANIZATION AND ANY FOLLOW UP REPORTS ON THE USE OF GRANT FUNDS.

Schedule I (Form 990) 2019

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Schedule J
(Form 990)

Department of the Treasury
Internal Revenue Service

Compensation Information

For certain Officers, Directors, Trustees, Key Employees, and Highest
Compensated Employees
SchJMediumBullet

Complete if the organization answered "Yes" on Form 990, Part IV, line 23.
SchJMediumBullet

Attach to Form 990.
SchJMediumBullet

Go to www.irs.gov/Form990 for instructions and the latest information.

OMB No. 1545-0047

2019

Open to Public Inspection

Name of the organization

SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION

Employer identification number

32-0178959

Part I

Questions Regarding Compensation

Yes

Check the appropiate box(es) if the organization provided any of the following to or for a person listed on Form
990, Part VII, Section A, line 1a. Complete Part III to provide any relevant information regarding these items.

First-class or charter travel Housing allowance or residence for personal use

Travel for companions Payments for business use of personal residence

Tax idemnification and gross-up payments Health or social club dues or initiation fees

Discretionary spending account Personal services (e.g., maid, chauffeur, chef)

If any of the boxes on Line 1a are checked, did the organization follow a written policy regarding payment or reimbursement or provision of all of the expenses described above? If "No," complete Part III to explain .........

Yes

Did the organization require substantiation prior to reimbursing or allowing expenses incurred by all
directors, trustees, officers, including the CEO/Executive Director, regarding the items checked on Line 1a? ..

Yes

Indicate which, if any, of the following the filing organization used to establish the compensation of the
organization's CEO/Executive Director. Check all that apply. Do not check any boxes for methods
used by a related organization to establish compensation of the CEO/Executive Director, but explain in Part III.

Compensation committee Written employment contract

Independent compensation consultant Compensation survey or study

Form 990 of other organizations Approval by the board or compensation committee

During the year, did any person listed on Form 990, Part VII, Section A, line 1a, with respect to the filing organization or a related organization:

Receive a severance payment or change-of-control payment? .............

Participate in, or receive payment from, a supplemental nonqualified retirement plan? .........

Yes

Participate in, or receive payment from, an equity-based compensation arrangement? .........

If "Yes" to any of lines 4a-c, list the persons and provide the applicable amounts for each item in Part III.

Only 501(c)(3), 501(c)(4), and 501(c)(29) organizations must complete lines 5-9.

For persons listed on Form 990, Part VII, Section A, line 1a, did the organization pay or accrue any
compensation contingent on the revenues of:

The organization? ....................

Any related organization? .......................

If "Yes," on line 5a or 5b, describe in Part III.

For persons listed on Form 990, Part VII, Section A, line 1a, did the organization pay or accrue any
compensation contingent on the net earnings of:

The organization? ..................

Any related organization? ......................

If "Yes," on line 6a or 6b, describe in Part III.

For persons listed on Form 990, Part VII, Section A, line 1a, did the organization provide any nonfixed
payments not described in lines 5 and 6? If "Yes," describe in Part III ............

Were any amounts reported on Form 990, Part VII, paid or accured pursuant to a contract that was
subject to the initial contract exception described in Regulations section 53.4958-4(a)(3)? If "Yes," describe
in Part III ..........................

If "Yes" on line 8, did the organization also follow the rebuttable presumption procedure described in Regulations section 53.4958-6(c)? .........................

For Paperwork Reduction Act Notice, see the Instructions for Form 990.

Cat. No. 50053T

Schedule J (Form 990) 2019

Page 2

Part II

Officers, Directors, Trustees, Key Employees, and Highest Compensated Employees. Use duplicate copies if additional space is needed.

For each individual whose compensation must be reported on Schedule J, report compensation from the organization on row (i) and from related organizations, described in the
instructions, on row (ii). Do not list any individuals that are not listed on Form 990, Part VII.
Note. The sum of columns (B)(i)-(iii) for each listed individual must equal the total amount of Form 990, Part VII, Section A, line 1a, applicable column (D) and (E) amounts for that individual.

(A) Name and Title		(B) Breakdown of W-2 and/or 1099-MISC compensation			(C) Retirement and other deferred compensation	(D) Nontaxable benefits	(E) Total of columns (B)(i)-(D)	(F) Compensation in column (B) reported as deferred on prior Form 990
(A) Name and Title		(i) Base compensation	(ii) Bonus & incentive compensation	(iii) Other reportable compensation	(C) Retirement and other deferred compensation	(D) Nontaxable benefits	(E) Total of columns (B)(i)-(D)
1KENNETH E BENTSEN JR PRESIDENT & CEO	(i) (ii)	1,483,844 ------------- 0	975,000 ------------- 0	5,544 ------------- 0	33,600 ------------- 0	47,532 ------------- 0	2,545,520 ------------- 0	0 ------------- 0
2JOSEPH SEIDEL COO	(i) (ii)	683,828 ------------- 0	400,000 ------------- 0	4,356 ------------- 0	16,013 ------------- 0	47,309 ------------- 0	1,151,506 ------------- 0	0 ------------- 0
3IRA D HAMMERMAN EVP/GC (SEE SCH. J 457 FN)	(i) (ii)	577,024 ------------- 0	400,000 ------------- 0	8,804 ------------- 0	33,600 ------------- 0	44,352 ------------- 0	1,063,780 ------------- 0	0 ------------- 0
4DAVID B KRASNER CFO & CAO	(i) (ii)	392,652 ------------- 0	295,000 ------------- 0	3,612 ------------- 0	33,600 ------------- 0	45,545 ------------- 0	770,409 ------------- 0	0 ------------- 0
5TIMOTHY W CAMERON MANAGING DIRECTOR	(i) (ii)	421,567 ------------- 0	190,000 ------------- 0	5,544 ------------- 0	33,600 ------------- 0	35,372 ------------- 0	686,083 ------------- 0	0 ------------- 0
6CHERYL L CRISPEN EXECUTIVE PRESIDENT	(i) (ii)	361,428 ------------- 0	227,500 ------------- 0	1,932 ------------- 0	33,600 ------------- 0	7,315 ------------- 0	631,775 ------------- 0	0 ------------- 0
7JAMIE WALL EXECUTIVE VICE PRESIDENT	(i) (ii)	443,562 ------------- 0	120,000 ------------- 0	594 ------------- 0	8,400 ------------- 0	3,867 ------------- 0	576,423 ------------- 0	0 ------------- 0
8VICTORIA CUMINGS MANAGING DIRECTOR	(i) (ii)	337,991 ------------- 0	180,000 ------------- 0	660 ------------- 0	33,600 ------------- 0	16,893 ------------- 0	569,144 ------------- 0	0 ------------- 0
9ROBERT TOOMEY MANAGING DIRECTOR	(i) (ii)	335,357 ------------- 0	145,000 ------------- 0	5,544 ------------- 0	35,994 ------------- 0	44,353 ------------- 0	566,248 ------------- 0	0 ------------- 0
10CARTER K MCDOWELL MANAGING DIRECTOR	(i) (ii)	407,917 ------------- 0	80,000 ------------- 0	5,544 ------------- 0	33,600 ------------- 0	35,504 ------------- 0	562,565 ------------- 0	0 ------------- 0
11MARK SCHUERMANN MANAGING DIRECTOR	(i) (ii)	422,117 ------------- 0	100,000 ------------- 0	2,720 ------------- 0	8,400 ------------- 0	16,435 ------------- 0	549,672 ------------- 0	0 ------------- 0
12SALVATORE CHIARELLI EXECUTIVE VICE PRESIDENT	(i) (ii)	226,200 ------------- 0	145,000 ------------- 0	1,932 ------------- 0	33,600 ------------- 0	32,373 ------------- 0	439,105 ------------- 0	0 ------------- 0

Schedule J (Form 990) 2019

Page 3

Part III

Supplemental Information

Provide the information, explanation, or descriptions required for Part I, lines 1a, 1b, 3, 4a, 4b, 4c, 5a, 5b, 6a, 6b, 7, and 8, and for Part II. Also complete this part for any additional information.

Return Reference	Explanation
PART I, LINE 1A	FIRST-CLASS TRAVEL PER THE EMPLOYMENT CONTRACT, SIFMA PROVIDED FIRST CLASS AIR TRAVEL WHEN TRAVELING FOR SIFMA BUSINESS FOR KENNETH E. BENTSEN, JR., PRESIDENT AND CEO. THE FIRST-CLASS AIR TRAVEL WAS EXCLUDED FROM TAXABLE COMPENSATION ON THE INDIVIDUAL'S FORM W-2 BECAUSE IT WAS INCURRED FOR BUSINESS REASONS.
PART I, LINE 4B	SUPPLEMENTAL NONQUALIFIED RETIREMENT PLAN EVP AND GENERAL COUNSEL PARTICIPATES IN A 457(B) PLAN. HE RECEIVED A TAXABLE PAYMENT OF $5,192 INCLUDED IN HIS W-2. IN ADDITION, EVP AND GENERAL COUNSEL ARE ELIGIBLE FOR PARTICIPATING INTO THE SECTION 457(F) PLAN. HOWEVER, SIFMA DID NOT CONTRIBUTE INTO THE 457(F) PLAN DURING CALENDAR YEAR 2019 FOR BOTH PARTICIPANTS.

Schedule J (Form 990) 2019

Additional Data

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SCHEDULE O
(Form 990 or 990-EZ)

Department of the Treasury
Internal Revenue Service

Supplemental Information to Form 990 or 990-EZ

Complete to provide information for responses to specific questions on
Form 990 or 990-EZ or to provide any additional information.
MediumBullet

Attach to Form 990 or 990-EZ.
MediumBullet

Go to www.irs.gov/Form990 for the latest information.

OMB No. 1545-0047

2019

Open to Public
Inspection

Name of the organization

SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION

Employer identification number

32-0178959

Return Reference	Explanation
GENERAL STATEMENT REGARDING COVID-19 IMPACT:	THE COVID-19 OUTBREAK HAS ADVERSELY IMPACTED THE LEVEL OF ECONOMIC ACTIVITY AROUND THE WORLD AND DISRUPTED NORMAL BUSINESS ACTIVITIES IN EVERY SECTOR OF THE ECONOMY. AS A RESULT OF THESE EVENTS, THE ASSOCIATION MOVED TO VIRTUAL EVENT PROGRAMS FOR THE BALANCE OF FISCAL YEAR 2020 AND EXPECTS TO CONTINUE WITH VIRTUAL PROGRAMMING UNTIL IN PERSON MEETINGS CAN SAFELY RESUME. IN EARLY 2020, THERE WAS AN OUTBREAK OF THE NOVEL STRAIN OF CORONAVIRUS ("COVID_19"). IN REACTION TO THE OUTBREAK, FEDERAL, STATE AND LOCAL GOVERNMENTS ISSUED MANDATES THAT DISRUPTED BUSINESSES AND RESULTED IN AN OVERALL DECLINE IN ECONOMIC ACTIVITY. DESPITE THE OPERATING CHALLENGES IT PRESENTED, SIFMA REMAINED FOCUSED ON DELIVERING ITS CORE MISSION. AS A RESULT, SIFMA WAS FORCED TO CLOSE OFFICES AND SHIFT ITS OPERATIONS, EVENTS AND EXEMPT PROGRAMS TO A REMOTE STATUS, WHICH REMAINED IN EFFECT THROUGH THE END OF FISCAL YEAR 2020 AND INTO FISCAL YEAR 2021. CONFERENCE REVENUE AND PUBLICATION REVENUE HAVE BEEN MATERIALLY IMPACTED, AS IN-PERSON EVENTS WERE CANCELLED OR MOVED TO VIRTUAL EVENTS AND CONNECTIONS WITH MEMBERS AND PEOPLE AFFECTED BY SIFMA TURNED TO ONLINE FORMATS. OVERALL, THE IMPACT WAS A REDUCTION OF 22% OF TOTAL REVENUE FOR THE YEAR ENDED OCTOBER 31, 2020, AS COMPARED TO THE PRIOR YEAR.
FORM 990, PART I, LINE 6:	VOLUNTEERS THE NUMBER OF VOLUNTEERS WAS DERIVED FROM SIFMA COMMITTEE PARTICIPANTS PER THE MEMBERSHIP DATABASE.
FORM 990, PART III, LINE 4A	STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS CONTINUED DEVELOPMENT AND MAINTENANCE OF BEST PRACTICES THAT ARE CONDUCIVE TO EFFICIENT CONDUCT OF THE BUSINESS AND MEMBERS OF THE ORGANIZATION: BUSINESS CONTINUITY PLANNING: THE FINANCIAL SERVICES SECTOR IS CRITICAL INFRASTRUCTURE AS DEFINED BY THE U.S. DEPARTMENT OF HOMELAND SECURITY. ITS ASSETS, SYSTEMS AND NETWORKS, WHETHER PHYSICAL OR VIRTUAL, ARE SO VITAL TO THE U.S. THAT THEIR INCAPACITATION OR IMPAIRMENT WOULD HAVE A DEBILITATING EFFECT ON NATIONAL AND ECONOMIC SECURITY AND PUBLIC HEALTH OR SAFETY. NOW MORE THAN EVER, AMIDST A GLOBAL HEALTH CRISIS AND WITH CYBERATTACKS AN EVER-INCREASING RISK, BUSINESS CONTINUITY PLANNING AND CONSTANT TESTING AND PREPAREDNESS IS ESSENTIAL. ON BEHALF OF OUR MEMBERS, SIFMA PLAYS A CRUCIAL ROLE IN HELPING COORDINATE THE FINANCIAL INDUSTRY'S BUSINESS CONTINUITY PLANNING (BCP) EFFORTS. SIFMA CONTINUES TO CLOSELY MONITOR COVID-19 AND ITS IMPACT ON THE FINANCIAL INDUSTRY AND THE CAPITAL MARKETS. THE VERY PANDEMIC SCENARIO THE INDUSTRY CONTEMPLATED IN 2007 - AND WHICH HAS BEEN USED IN BUSINESS CONTINUITY PLANNING EXERCISES SINCE - BECAME REAL-WORLD REALITY IN 2020. WHEN PUBLIC HEALTH OFFICIALS INSTITUTED MASS CLOSINGS, THE INDUSTRY WAS READY AND SIFMA HAD A PLAYBOOK TO FOLLOW. FROM THE OUTSET OF THIS CRISIS, SIFMA ARRANGED COORDINATION AMONGST FINANCIAL FIRMS, EXCHANGES, INDUSTRY UTILITIES, REGULATORS, GOVERNMENT AGENCIES AND PUBLIC SECTOR EMERGENCY COORDINATORS. FIRMS ACTIVATED RESPONSE PROTOCOLS ALL WHILE MANAGING HISTORIC TRADING VOLUMES. DESPITE SIGNIFICANT OBSTACLES, THE INDUSTRY KEPT THE MARKETS OPEN AND RUNNING, CONTINUED TO SERVE AND ADVISE CLIENTS, AND ENSURED TIMELY CLEARANCE AND SETTLEMENT ACTIVITIES. THIS EFFORT SHOULD PROVIDE CONFIDENCE THE INDUSTRY CAN SUCCESSFULLY NAVIGATE FUTURE TURMOIL OR UNCERTAINTY, BE IT A NATURAL DISASTER, HEALTH CRISIS, SOCIAL UNREST OR OTHERWISE. CYBERSECURITY: CYBERSECURITY HAS BEEN AND REMAINS A TOP PRIORITY FOR THE FINANCIAL SERVICES INDUSTRY TO ENSURE THE SECURITY OF CUSTOMER ASSETS AND INFORMATION AND THE EFFICIENT, RELIABLE EXECUTION OF MARKET OPERATIONS. RISK IS HEIGHTENED DURING TIMES OF UNCERTAINTY, INCLUDING A GLOBAL PANDEMIC. AN EFFECTIVE AND EFFICIENT CYBERSECURITY POLICY IS ACHIEVED MOST EASILY THROUGH HARMONIZED, RISK-BASED GLOBAL STANDARDS THAT LEVERAGE EXTENSIVE INVESTMENTS ALREADY MADE. 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. SIFMA CONTINUALLY WORKS WITH INDUSTRY AND GOVERNMENT LEADERS TO IDENTIFY AND COMMUNICATE CYBERSECURITY BEST PRACTICES FOR FIRMS OF ALL SIZES AND CAPABILITIES AND EDUCATE THE INDUSTRY ON EVOLVING THREATS AND APPROPRIATE RESPONSES. DIVERSE & INCLUSIVE FINANCIAL INDUSTRY: SIFMA AND ITS MEMBERS STRIVE TO PROVIDE FIRMS ACROSS THE FINANCIAL SERVICES INDUSTRY WITH THE RESOURCES NEEDED TO ACHIEVE, EXPAND AND PROMOTE WORKFORCE, CLIENT, AND SUPPLIER DIVERSITY AND INCLUSION. THROUGH SIFMA'S DIVERSITY & INCLUSION ADVISORY COUNCIL, WE ASSIST MEMBER FIRMS IN DEVELOPING THEIR DIVERSITY INITIATIVES TO INCREASE INCLUSION IN THE WORKPLACE AND IN THEIR EFFORTS TO MARKET TO DIVERSE CUSTOMERS. FOR MORE THAN 20 YEARS, THE COUNCIL HAS CONDUCTED A BENCHMARK SURVEY AND ENCOURAGES MORE OF OUR MEMBER FIRMS TO PARTICIPATE. SIFMA RECOGNIZES THAT ACHIEVING DIVERSITY IS AN EVOLUTIONARY PROCESS THAT REQUIRES AN ONGOING COMMITMENT TO DIVERSITY POLICIES AND PRACTICES, AS WELL AS REGULAR ASSESSMENTS TO EVALUATE THE EFFECTIVENESS OF WORKFORCE AND EMPLOYMENT PRACTICES, BUSINESS PRACTICES AND SUPPLIER DIVERSITY, AND TRANSPARENCY OF ORGANIZATIONAL DIVERSITY AND INCLUSION. DIVERSITY AND INCLUSION IN THE FINANCIAL SERVICES INDUSTRY REMAINS A SIFMA BOARD PRIORITY AND OF UTMOST IMPORTANCE. SIFMA LOOKS FORWARD TO CONTINUING OUR LEADERSHIP ROLE IN THE FUTURE.
FORM 990, PART III, LINE 4B	STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS ADVOCACY: ADVOCACY FOR ISSUES OF IMPORTANCE TO ITS MEMBERS: SIFMA BRINGS TOGETHER THE SHARED INTERESTS OF HUNDREDS OF BROKER-DEALERS, BANKS AND ASSET MANAGERS. WE ADVOCATE IN SUPPORT OF EFFECTIVE AND RESILIENT CAPITAL MARKETS. 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. SIFMA'S 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. IMPROVING AMERICAN INFRASTRUCTURE THROUGH MUNICIPAL FINANCE: SIFMA AND ITS MEMBER FIRMS SUPPORT THE PRESERVATION OF THE TAX EXEMPTION FOR MUNICIPAL BONDS AS WELL AS FOUR MAIN INITIATIVES THAT HELP PROMOTE INCREASED BOND FINANCING AND FUND IMPORTANT INFRASTRUCTURE-RELATED PROJECTS WHILE ALSO SAVING TAXPAYER DOLLARS: 1. SECURE THE PASSAGE OF LEGISLATION PERMITTING ISSUERS TO ADVANCE REFUND TAX-EXEMPT MUNICIPAL DEBT; 2. AUTHORIZE A NEW DIRECT PAYMENT BOND PROGRAM ON A PERMANENT BASIS; 3. EXPAND THE VOLUME CAP AND USES FOR PRIVATE ACTIVITY BONDS (PABS); AND 4. INCREASE THE ANNUAL LIMIT ON THE AMOUNT OF TAX-EXEMPT OBLIGATIONS THAT MAY BE ISSUED TO QUALIFY FOR THE SMALL ISSUER EXCEPTION TO THE TAX-EXEMPT INTEREST EXPENSE ALLOCATION RULES. SIFMA SUPPORTS A NUMBER OF INITIATIVES RELATED TO MUNICIPAL FINANCE, INCLUDING REINSTATING THE TAX EXEMPTION FOR ADVANCE REFUNDING BONDS; AUTHORIZING A NEW DIRECT PAY BOND PROGRAM ON A PERMANENT BASIS AS A SUPPLEMENT TO, NOT A REPLACEMENT FOR, TAX-EXEMPT BONDS; PERMITTING STATE AND LOCAL GOVERNMENTS TO ISSUE TAX-EXEMPT BONDS FOR INFRASTRUCTURE PROJECTS WITH PRIVATE PARTICIPATION IN THE SAME MANNER THAT THEY ISSUE BONDS FOR PURELY PUBLIC PROJECTS, AND ALSO EXPANDING THE VOLUME CAP AND PERMITTED USES OF PRIVATE ACTIVITY BONDS (PABS); AND EXPANDING THE NUMBER OF "BANK-QUALIFIED" BONDS FROM THE CURRENT LIMIT OF $10 MILLION TO $30 MILLION WITH INFLATION ADJUSTMENTS FOR FUTURE YEARS. FINANCING SUSTAINABILITY: SIFMA AND SIFMA'S ASSET MANAGEMENT GROUP (AMG) ARE WORKING CLOSELY WITH OUR PARTNERS AT THE GLOBAL FINANCIAL MARKETS ASSOCIATION (GFMA) ON ISSUES LIKE ACCELERATING THE EVOLUTION OF CAPITAL MARKETS' CLIMATE FINANCE MARKET STRUCTURE (CFMS) AND PROVIDING MARKET INSIGHTS AS REGULATORS AROUND THE WORLD DEVELOP STANDARDS TO SUPPORT MOBILIZATION OF CAPITAL FOR CLIMATE FINANCE. SIFMA WILL CONTINUE TO WORK ON EDUCATIONAL EFFORTS REGARDING ESG INVESTING IN THE U.S. AND ABROAD. TRANSITIONING FROM LIBOR TO ALTERNATIVE REFERENCE RATES: SIFMA AND OUR PARTNERS AT THE GLOBAL FINANCIAL MARKETS ASSOCIATION (GFMA) WERE EARLY PROPONENTS OF GLOBAL REFORM EFFORTS WITH THE NOVEMBER 2012 PUBLICATION OF PRINCIPLES FOR FINANCIAL BENCHMARKS. SINCE THAT TIME, WE HAVE ENGAGED WITH AND ARE SUPPORTIVE OF EFFORTS BY GLOBAL REGULATORY BODIES RELATED TO MARKET STANDARDS AND PRINCIPLES FOR BENCHMARKS. IN JUNE 2017, THE FEDERAL RESERVE'S ALTERNATIVE REFERENCE RATE COMMITTEE (ARRC) SELECTED THE SECURED OVERNIGHT FUNDING RATE (SOFR) AS THE RATE THAT, IN ITS CONSENSUS VIEW, REPRESENTS BEST PRACTICE FOR USE IN CERTAIN NEW U.S. DOLLAR DERIVATIVES AND OTHER FINANCIAL CONTRACTS. SIFMA IS COMMITTED TO WORKING IN CLOSE COOPERATION WITH THE INDUSTRY, U.S. AND GLOBAL REGULATORS, AND TRADE ASSOCIATIONS AS A MEMBER OF THE FEDERAL RESERVE'S ALTERNATIVE REFERENCE RATE COMMITTEE (ARRC). ISSUES SIFMA IS FOCUSED ON INCLUDE: LEGACY TRANSACTIONS, IMPLEMENTATION OF ROBUST FALLBACK PROVISIONS, AND DEVELOPMENT OF TERM RATES IN SUPPORT OF A SUCCESSFUL TRANSITION TO ALTERNATIVE REFERENCE RATES. IMPLEMENTING THE CONSOLIDATED AUDIT TRAIL: THE SEC AND THE SELF REGULATORY ORGANIZATIONS (SROS) CONTINUE TO DEVELOP A COMPREHENSIVE CONSOLIDATED AUDIT TRAIL (CAT) THAT WOULD ENABLE REGULATORS TO 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. SIFMA ADVOCATES FOR A SECURE SYSTEM THAT EXPEDITES THE RETIREMENT OF DUPLICATIVE SYSTEMS, WHILE PROMOTING AN INCLUSIVE GOVERNANCE STRUCTURE AND EQUITABLE FUNDING MODEL. SIFMA HAS EXPRESSED CONCERNS AROUND RISKS RELATED TO THE COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION (PII) WITHIN THE CAT AND WORKED WITH THE SEC AND THE SRO'S AS THEY MAKE SIGNIFICANT STEPS FORWARD IN HOLDING THE CAT TO THE HIGHEST SECURITY STANDARDS. DIGITALIZATION AND SECURITY TOKENS: U.S. CAPITAL MARKETS HAVE CONTINUED TO INNOVATE AS TECHNOLOGY HAS ALLOWED FOR PROFOUND EVOLUTIONS IN MARKET INFRASTRUCTURE, CHANGING AT TIMES THE VERY NATURE OF AMERICAN FINANCIAL MARKETS. DISTRIBUTED LEDGER TECHNOLOGY (DLT) AND THE POTENTIAL BENEFIT IT MAY BRING TO THE CAPITAL MARKET ECOSYSTEM AND INFRASTRUCTURE ARE A KEY TOPIC OF INTEREST AMONGST MARKET PARTICIPANTS. SIFMA AND PRICEWATERHOUSECOOPERS LLP PUBLISHED A PAPER, SECURITY TOKENS: CURRENT REGULATORY AND OPERATIONAL CONSIDERATIONS FOR BROKER-DEALERS AND A LOOK TOWARDS THE FUTURE. THE PAPER PROVIDES A FOUNDATIONAL UNDERSTANDING OF HOW DLT AND DIGITAL ASSETS SUCH AS SECURITY TOKENS CAN OFFER NEW AND COST-EFFICIENT METHODS OF CAPITAL FORMATION. IT ALSO DESCRIBES THE KEY OPERATIONAL CHALLENGES FACED BY U.S. BROKER-DEALERS HOPING TO ADOPT THIS TECHNOLOGY AND RECOMMENDS WHERE REGULATORY CLARITY WOULD BE HELPFUL IN ADDRESSING THESE CHALLENGES. SIFMA DEVELOPED THE PAPER IN COLLABORATION WITH ITS MEMBER WORKING GROUPS, AND DETERMINED AND IDENTIFIED THE ACTIVITIES, REQUIREMENTS, AND CONSIDERATIONS FOR MARKET PARTICIPANTS ENGAGING IN OPERATIONALIZING SECURITY TOKENS. HELPING BUSINESSES AND INVESTORS MANAGE RISK: TITLE VII OF THE DODD FRANK ACT ESTABLISHED A BROAD NEW REGULATORY REGIME FOR OVER-THE-COUNTER (OTC) DERIVATIVES, OR SWAPS, WHICH IS PROFOUNDLY AFFECTING THE FINANCIAL MARKETS AND MARKET PARTICIPANTS. SUFFICIENTLY LIQUID AND STANDARD SWAPS ARE SUBJECT TO MANDATORY CLEARING, WHICH REQUIRES TRANSACTIONS TO BE SUBMITTED TO A CENTRAL COUNTERPARTY. FURTHER, CERTAIN CLEARED TRANSACTIONS ARE REQUIRED TO BE EXECUTED ON ELECTRONIC TRADING PLATFORMS, SUCH AS SWAP EXECUTION FACILITIES OR DESIGNATED CONTRACT MARKETS. HOWEVER, SOME SWAPS WILL APPROPRIATELY REMAIN BILATERALLY CLEARED AND/OR TRADED. SIFMA BELIEVES THAT THE DODD-FRANK ACT TOOK SEVERAL IMPORTANT AND NECESSARY STEPS TOWARDS IMPROVING OVERSIGHT AND TRANSPARENCY IN THE SWAPS MARKETS AND SUPPORTS THE IMPLEMENTATION OF APPROPRIATE REGULATIONS THAT DO NOT CREATE UNDUE COSTS OR UNDULY LIMIT THE AVAILABILITY OF THESE VALUABLE RISK MANAGEMENT TOOLS FOR AMERICAN BUSINESSES. HELPING MORE AMERICANS SAVE FOR RETIREMENT: SIFMA SUPPORTS THE SECURING A STRONG RETIREMENT ACT 0F 2020 (SECURE ACT), INTRODUCED BY HOUSE WAYS AND MEANS COMMITTEE CHAIRMAN RICHARD E. NEAL (D-MA) AND RANKING MEMBER KEVIN BRADY (R-TX). THE BILL REPRESENTS IMPORTANT STEPS TOWARD ENHANCING THE PRIVATE RETIREMENT SYSTEM AND INCREASING RETIREMENT SAVINGS. IT INCLUDES PROVISIONS THAT WILL INCENTIVIZE SMALL BUSINESS TO OFFER RETIREMENT PLANS, ENABLE OLDER AMERICANS TO SAVE MORE AND HOLD ON TO THEIR SAVINGS LONGER, AND ALLOW MATCHING CONTRIBUTIONS FOR STUDENT LOAN PAYMENTS. ENHANCING INVESTOR PROTECTION WHILE PRESERVING CHOICE: REGULATION BEST INTEREST FINALIZED BY THE SECURITIES AND EXCHANGE COMMISSION IN 2019 AND FULLY ENFORCEABLE AS OF JUNE 2020 SIGNIFICANTLY AND MEANINGFULLY UPGRADES THE EXISTING REGULATORY REGIME FOR BROKER-DEALERS, AND DIRECTLY ENHANCES INVESTOR PROTECTION. SIFMA ADVOCATED FOR THE CREATION OF SUCH A STANDARD FOR OVER A DECADE. THE RULE IS SPECIFIC WITH RESPECT TO THE OBLIGATIONS BROKERS OWE TO THEIR CLIENTS AND THE STEPS THEY MUST TAKE TO COMPLY, INCLUDING THE OBLIGATION TO ELIMINATE, DISCLOSE AND MITIGATE CERTAIN CONFLICTS OF INTEREST. IT IS ENHANCING INVESTOR PROTECTIONS, WHILE ALSO PRESERVING INVESTOR CHOICE AND ACCESS TO INVESTMENT ADVICE.
FORM 990, PART III, LINE 4B	REG BI SUBSTANTIALLY EXCEEDS THE PRECEDING FINRA SUITABILITY STANDARD AND IS BROADER IN SCOPE THAN THE NOW DEFUNCT DOL FIDUCIARY RULE. REG BI APPLIES ACROSS ALL CUSTOMER ACCOUNTS, NOT JUST RETIREMENT ACCOUNTS, AND WILL ALLOW THE SEC TO ENFORCE A COMMON STANDARD ACROSS THE INDUSTRY. ATTEMPTS BY CONGRESS TO WEAKEN REG BI WOULD HURT INVESTOR PROTECTIONS IMPLEMENTED BY BROKERS. SAFEGUARDING INVESTOR PRIVACY: SIFMA SUPPORTS DATA PRIVACY POLICIES, WHICH TAKE INTO ACCOUNT EXISTING, STRONG FEDERAL RULES UNDER THE GRAMM-LEACH-BLILEY ACT THAT ENSURE FIRMS MAINTAIN PRIVACY IN THEIR CLIENT RELATIONS AND TRANSPARENCY IN HOW DATA IS BEING USED AND PROTECTED. DATA PRIVACY IS A TOP PRIORITY FOR FINANCIAL FIRMS. INVESTORS ARE INCREASINGLY LOOKING FOR TRANSPARENCY AS THEY DETERMINE HOW THEIR DATA IS BEING USED AND HOW IT IS BEING PROTECTED. SIFMA SUPPORTS A FEDERAL PRIVACY FRAMEWORK THAT WOULD PREEMPT STATE LAW, AS MANY OF OUR FIRMS FUNCTION REGIONALLY, NATIONALLY, AND GLOBALLY. IN FINANCIAL SERVICES, THE GRAMM-LEACH-BLILEY ACT, HAS SERVED AS THE CORNERSTONE FOR THE INDUSTRY'S DATA PRIVACY FRAMEWORK. SHOULD THERE BE A CHANGE TO HOW DATA PRIVACY IS HANDLED AT THE FEDERAL LEVEL, IT IS CRITICAL THAT ANY FRAMEWORK TAKE INTO CONSIDERATION HOW CHANGES TO PRIVACY LAW WOULD AFFECT THE GRAMM-LEACH-BLILEY ACT. BUILDING THE INDEPENDENT CONTRACTOR MODEL: SIFMA SUPPORTS PRESERVATION OF THE INDEPENDENT CONTRACTOR STATUS IN THE FINANCIAL SERVICES INDUSTRY WHERE INDEPENDENT BROKER-DEALER AND INDEPENDENT FINANCIAL ADVISORS CAN PROVIDE SERVICES TO THEIR RETAIL AND INSTITUTIONAL CLIENTS. THE GIG ECONOMY HAS CHANGED THE LABOR LANDSCAPE IN THE UNITED STATES DRASTICALLY IN RECENT YEARS. MANY OF THESE WORKERS ARE CLASSIFIED AS INDEPENDENT CONTRACTORS UNDER THE NATIONAL LABOR RELATIONS ACT (NLRA). THERE IS DEBATE AS TO WHETHER THIS IS AN APPROPRIATE CLASSIFICATION FOR THOSE WORKERS; HOWEVER, IN THE FINANCIAL SERVICES INDUSTRY, MANY BROKERS AND ADVISORS CHOOSE TO OPERATE AS INDEPENDENT CONTRACTORS. TAX POLICY SUPPORTING ECONOMIC GROWTH: TAXES IMPACT THE SAVINGS AND INVESTMENT DECISIONS OF INDIVIDUALS AND CORPORATIONS AND ARE A NECESSARY MEANS FOR FUNDING THE GOVERNMENT. SIFMA BELIEVES REASONABLE TAXATION AND ECONOMIC GROWTH ARE NOT MUTUALLY EXCLUSIVE AND ENCOURAGES POLICY MAKERS TO CONSIDER BOTH WHEN CONTEMPLATING CHANGES TO THE TAX CODE. MANY OF SIFMA'S MEMBERS ARE GLOBAL TAXPAYERS AS WELL, THEREFORE INTERNATIONAL STANDARDS FOR RAISING REVENUE SHOULD CONSIDER THE HIGHLY REGULATED NATURE OF THE FINANCIAL SERVICES INDUSTRY. SIFMA'S MEMBER FIRMS ARE WILLING AND PREPARED TO HELP POLICYMAKERS WADE THROUGH THE NUANCES AND GOALS OF THEIR RESPECTIVE TAX POLICY. EXAMINING THE INTERPLAY OF FINANCE AND INTERNATIONAL POLICY: MODERN CAPITAL MARKETS OPERATE IN AN INHERENTLY CROSS-BORDER FRAMEWORK. SIFMA SUPPORTS AN OPEN, RULES BASED, GLOBAL ECONOMY IN WHICH FINANCIAL SERVICES CAN DO ITS PART TO BOOST EXPORTS, INVESTMENT AND GLOBAL ECONOMIC GROWTH. PRUDENTIAL REGULATION OF THE CAPITAL MARKETS: PRUDENTIAL REGULATION REQUIRES FINANCIAL FIRMS TO CONTROL RISKS, HOLD ADEQUATE CAPITAL AND LIQUIDITY, AND HAVE IN PLACE WORKABLE RECOVERY AND RESOLUTION PLANS. IT IS ESSENTIAL THAT OUR REGULATORY REGIME ACCOUNTS FOR THE VITAL ROLE THE CAPITAL MARKETS PLAY IN PROVIDING CREDIT AND FINANCING THE REAL ECONOMY. SIFMA SUPPORTS APPROPRIATE REGULATION OF THE CAPITAL MARKETS AND THEIR PARTICIPANTS BY BOTH MARKET REGULATORS, WHO HAVE DECADES OF EXPERIENCE IN PROMULGATING RULES AND SUPERVISING THE MARKETPLACE, AS WELL AS PRUDENTIAL REGULATORS. UNFORTUNATELY, TOO OFTEN THESE PRUDENTIAL RULES TREAT CAPITAL MARKETS ACTIVITIES AS RISKIER THAN COMMERCIAL LENDING ACTIVITIES WITHOUT EVIDENCE TO SUPPORT THIS POSITION TAKEN BY THE PRUDENTIAL REGULATORS. U.S. PRUDENTIAL RULES GENERALLY IMPOSE SIGNIFICANTLY HIGHER CAPITAL AND LIQUIDITY COSTS ON BANKING ENTITIES WITH SIGNIFICANT CAPITAL MARKETS OPERATIONS. THIS HAS INCREASED COSTS TO FINANCIAL FIRMS AND THE ECONOMY AS A WHOLE AND REDUCED MARKET DEPTH FOR A WIDE VARIETY OF CORPORATIONS AND OTHER END-USERS, PARTICULARLY DURING PERIODS OF ECONOMIC STRESS. THIS HAS ALSO HAD ANOTHER EFFECT: TRANSFORMING U.S. BANKING REGULATORS INTO THE MOST IMPACTFUL SUPERVISOR OF THE CAPITAL MARKETS SUPERSEDING THE OVERSIGHT ROLE TRADITIONALLY PLAYED BY THE SEC AND CFTC. THIS HAS CREATED DISTORTIONS IN THE CAPITAL AND LIQUIDITY REQUIREMENTS BETWEEN MARKET AND PRUDENTIAL REGULATORS AS WELL AS LESSENED THE EFFICIENCIES BY INCREASING COSTS TO END USERS.
FORM 990, PART III, LINE 4C	STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS CONFERENCES AND SEMINARS: SIFMA CONFERENCES, EVENTS AND WEBINARS FOSTER MEANINGFUL CONVERSATIONS ABOUT THE CAPITAL MARKETS AND OFFER VALUABLE PROFESSIONAL DEVELOPMENT OPPORTUNITIES. OUR OFFERINGS PIVOT QUICKLY BASED ON THE CURRENT ENVIRONMENT. SIFMA ANNUAL MEETING: FOR NEARLY 50 YEARS, SIFMA'S ANNUAL MEETING HAS BEEN THE PLACE WHERE THE CAPITAL MARKETS MEET. SIFMA GATHERS THE MOST INFLUENTIAL VOICES SHAPING TODAY'S CAPITAL MARKETS TO CHALLENGES AND GAIN INSIGHTS INTO OPPORTUNITIES AHEAD. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR: SIFMA'S C&L ANNUAL SEMINAR HAS SERVED AS THE PREEMINENT EVENT FOR COMPLIANCE AND LEGAL PROFESSIONALS WORKING IN FINANCIAL SERVICES. THROUGHOUT THE PROGRAM, PARTICIPANTS HEAR DIRECTLY FROM INDUSTRY LEADERS AND REGULATORS ON THE LATEST DEVELOPMENTS AND TRENDS AND BUILD PROFESSIONAL RELATIONSHIPS TO COLLABORATE BETTER. WITH FOCUSED DISCUSSIONS BY NOTED KEYNOTE SPEAKERS AND SUBJECT MATTER EXPERTS, ATTENDEES WILL HAVE THE OPPORTUNITY TO EARN CLE CREDIT, INCLUDING DIVERSITY AND ETHICS CREDIT, AND NETWORK WITH PEERS. OPERATIONS CONFERENCE & EXHIBITION: THE OPERATIONS CONFERENCE & EXHIBITION BRINGS TOGETHER OPERATIONS, TECHNOLOGY AND REGULATORY LEADERS FROM ACROSS THE SECURITIES INDUSTRY FOR THREE DAYS OF DISCUSSIONS, ADDRESSING THE MOST CRITICAL PRIORITIES. 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 SECURITIES INDUSTRY PROFESSIONALS, HOSTED BY SIFMA AND WHARTON. FOR 69 YEARS, SIFMA AND THE WHARTON SCHOOL HAVE PARTNERED TO DEVELOP THE INDUSTRY'S HIGH-POTENTIAL RISING LEADERS. OVER THREE CONSECUTIVE YEARS SII PARTICIPANTS DEVELOP LEADERSHIP AND MANAGERIAL SKILLS AND ENHANCE INVESTMENT AND INDUSTRY KNOWLEDGE. SII'S 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.
FORM 990, 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 - ASSOCIATE MEMBERS
FORM 990, PART VI, SECTION A, LINE 7A	SIMFA IS A MEMBERSHIP ORGANIZATION AND MEMBERS HAVE THE FOLLOWING POWERS WITH RESPECT TO THE GOVERNING BODY: 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.
FORM 990, PART VI, SECTION B, LINE 11B	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.
FORM 990, 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.
FORM 990, 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 AND COO HAVE EMPLOYMENT CONTRACTS WHICH WERE 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.
FORM 990, 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.
FORM 990, PART XI, LINE 9:	POST-RETIREMENT RELATED CHANGES OTHER THAN NET PERIODIC POST RETIREMENT BENEFIT COST 230,310. OTHER NONOPERATING EXPENSES -149,030.

For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.

Cat. No. 51056K

Schedule O (Form 990 or 990-EZ) 2019

Additional Data

Software ID:
Software Version:

1	Briefly describe the organization’s mission or most significant activities: SIFMA IS THE LEADING TRADE ASSOCIATION FOR BROKER-DEALERS, INVESTMENT BANKS AND ASSET MANAGERS OPERATING IN THE U.S. AND GLOBAL CAPITAL MARKETS.
2	Check this box
3	Number of voting members of the governing body (Part VI, line 1a) ........	3	41
4	Number of independent voting members of the governing body (Part VI, line 1b) .....	4	40
5	Total number of individuals employed in calendar year 2019 (Part V, line 2a) ......	5	160
6	Total number of volunteers (estimate if necessary) .............	6	15,293
7a	Total unrelated business revenue from Part VIII, column (C), line 12 ........	7a	134,952
b	Net unrelated business taxable income from Form 990-T, line 39 .........	7b	49,272

		Prior Year	Current Year
8	Contributions and grants (Part VIII, line 1h) .........	0	0
9	Program service revenue (Part VIII, line 2g) .........	55,921,747	44,084,483
10	Investment income (Part VIII, column (A), lines 3, 4, and 7d ) ....	1,164,044	597,572
11	Other revenue (Part VIII, column (A), lines 5, 6d, 8c, 9c, 10c, and 11e)	901,585	716,844
12	Total revenue—add lines 8 through 11 (must equal Part VIII, column (A), line 12)	57,987,376	45,398,899
13	Grants and similar amounts paid (Part IX, column (A), lines 1–3 )...	257,539	167,248
14	Benefits paid to or for members (Part IX, column (A), line 4).....	0	0
15	Salaries, other compensation, employee benefits (Part IX, column (A), lines 5–10)	33,792,772	34,231,574
16a	Professional fundraising fees (Part IX, column (A), line 11e) .....	0	0
b	Total fundraising expenses (Part IX, column (D), line 25) 0
17	Other expenses (Part IX, column (A), lines 11a–11d, 11f–24e)....	23,287,406	15,929,592
18	Total expenses. Add lines 13–17 (must equal Part IX, column (A), line 25)	57,337,717	50,328,414
19	Revenue less expenses. Subtract line 18 from line 12.......	649,659	-4,929,515
		Beginning of Current Year	End of Year
20	Total assets (Part X, line 16).............	53,179,679	44,078,460
21	Total liabilities (Part X, line 26).............	30,403,710	25,514,963
22	Net assets or fund balances. Subtract line 21 from line 20.....	22,775,969	18,563,497

Sign Here

	Signature of officer	Date

	Type or print name and title


4a	(Code: ) (Expenses $ including grants of $ ) (Revenue $ )
	THE COVID-19 OUTBREAK HAS ADVERSELY IMPACTED THE LEVEL OF ECONOMIC ACTIVITY AROUND THE WORLD AND DISRUPTED NORMAL BUSINESS ACTIVITY IN EVERY SECTOR OF THE ECONOMY. AS A RESULT OF THESE EVENTS, SIFMA CANCELLED ITS LARGER IN PERSON CONFERENCES IN 2020 AND MOVED TO VIRTUAL PROGRAM SERVICES FOR THE BALANCE OF FISCAL YEAR 2020. SEE SCHEDULE O

4b	(Code: ) (Expenses $ including grants of $ ) (Revenue $ )
	SEE SCHEDULE O

4c	(Code: ) (Expenses $ including grants of $ ) (Revenue $ )
	SEE SCHEDULE O

	(Code: ) (Expenses $ including grants of $ ) (Revenue $ )
	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.

4d	Other program services (Describe in Schedule O.)
	(Expenses $ including grants of $ ) (Revenue $ )
4e	Total program service expenses

1b	Sub-Total................
c	Total from continuation sheets to Part VII, Section A....
d	Total (add lines 1b and 1c)...........	9,397,773	0	714,457

1a	Federated campaigns..	1a
b	Membership dues..	1b
c	Fundraising events..	1c
d	Related organizations	1d
e	Government grants (contributions)	1e

f	All other contributions, gifts, grants, and similar amounts not included above	1f

g	Noncash contributions included in lines 1a - 1f:$	1g

h Total. Add lines 1a-1f.......

		Business Code
2a	MEMBER DUES	541900	39,941,558	39,941,558
b	CONFERENCES	541900	4,082,997	4,082,997
c	PUBLICATION SALES	900099	59,928	59,928
d
e
f	All other program service revenue.
g	Total. Add lines 2a–2f .....		44,084,483

3 Investment income (including dividends, interest, and othersimilar amounts) ......			597,572			597,572
4 Income from investment of tax-exempt bond proceeds
5 Royalties...........			135,436			135,436
		(ii) Personal	(i) Real
6a	Gross rents			6a
b	Less: rental expenses			6b
c	Rental income or (loss)			6c
d	Net rental income or (loss).......
		(ii) Other	(i) Securities
7a	Gross amount from sales of assets other than inventory			7a
b	Less: cost or other basis and sales expenses			7b
c	Gain or (loss)			7c
d	Net gain or (loss).........
8a	Gross income from fundraising events (not including $ of contributions reported on line 1c). See Part IV, line 18 ....
			8a
b	Less: direct expenses ...		8b
c	Net income or (loss) from fundraising events..
9a	Gross income from gaming activities. See Part IV, line 19 ...
			9a
b	Less: direct expenses ...		9b
c	Net income or (loss) from gaming activities..
10a	Gross sales of inventory, less returns and allowances ..
			10a
b	Less: cost of goods sold ..		10b
c	Net income or (loss) from sales of inventory..
Business Code			Miscellaneous Revenue
11a	SHARED SERVICE AGREEMENTS		561000	444,444			444,444
b	MISCELLANEOUS REVENUE		900099	136,964		134,952	2,012
c
d	All other revenue ....
e	Total. Add lines 11a–11d ......			581,408
12	Total revenue. See instructions.....			45,398,899	44,084,483	134,952	1,179,464

1	Grants and other assistance to domestic organizations and domestic governments. See Part IV, line 21 ....	167,248
2	Grants and other assistance to domestic individuals. See Part IV, line 22 ...........
3	Grants and other assistance to foreign organizations, foreign governments, and foreign individuals. See Part IV, lines 15 and 16. .............
4	Benefits paid to or for members .......
5	Compensation of current officers, directors, trustees, and key employees ...........	7,343,501
6	Compensation not included above, to disqualified persons (as defined under section 4958(f)(1)) and persons described in section 4958(c)(3)(B) .........
7	Other salaries and wages........	21,561,324
8	Pension plan accruals and contributions (include section 401(k) and 403(b) employer contributions) ....	1,790,515
9	Other employee benefits .......	2,189,533
10	Payroll taxes ...........	1,346,701
11	Fees for services (non-employees):
a	Management ......	145,045
b	Legal .........	2,446,117
c	Accounting ...........	132,258
d	Lobbying ...........	590,522
e	Professional fundraising services. See Part IV, line 17
f	Investment management fees ......	69,312
g	Other (If line 11g amount exceeds 10% of line 25, column (A) amount, list line 11g expenses on Schedule O)	877,033
12	Advertising and promotion ....
13	Office expenses .......	614,087
14	Information technology ......	896,726
15	Royalties ..
16	Occupancy ...........	3,819,144
17	Travel ............	409,451
18	Payments of travel or entertainment expenses for any federal, state, or local public officials .
19	Conferences, conventions, and meetings ....	2,354,185
20	Interest ...........
21	Payments to affiliates .......
22	Depreciation, depletion, and amortization ..	1,925,636
23	Insurance ...
24	Other expenses. Itemize expenses not covered above (List miscellaneous expenses in line 24e. If line 24e amount exceeds 10% of line 25, column (A) amount, list line 24e expenses on Schedule O.)
a	SUBSCRIPTION AND BOOKS	536,051
b	BANK CHARGES & CC PROCE	356,709
c	DUES & REGISTRATION	146,188
d	PRINTING	55,902
e	All other expenses	555,226
25	Total functional expenses. Add lines 1 through 24e	50,328,414
26	Joint costs. Complete this line only if the organization reported in column (B) joint costs from a combined educational campaign and fundraising solicitation. Check here if following SOP 98-2 (ASC 958-720).

1	Cash–non-interest-bearing ........			1,851,438	1	1,299,649
2	Savings and temporary cash investments .........			18,069,354	2	18,871,390
3	Pledges and grants receivable, net ......				3
4	Accounts receivable, net .............			53,750	4	145,796
5	Loans and other payables to any current or former officer, director, trustee, key employee, creator or founder, substantial contributor, or 35% controlled entity or family member of any of these persons .......
					5
6	Loans and other receivables from other disqualified persons (as defined under section 4958(f)(1)), and persons described in section 4958(c)(3)(B) ...
					6
7	Notes and loans receivable, net ...........				7
8	Inventories for sale or use ............				8
9	Prepaid expenses and deferred charges ......			3,812,167	9	2,245,349
10a	Land, buildings, and equipment: cost or other basis. Complete Part VI of Schedule D	10a	25,644,418
b	Less: accumulated depreciation	10b	20,216,043	7,126,456	10c	5,428,375
11	Investments—publicly traded securities .			20,861,914	11	12,833,306
12	Investments—other securities. See Part IV, line 11 .....				12
13	Investments—program-related. See Part IV, line 11 ..				13
14	Intangible assets ...............				14
15	Other assets. See Part IV, line 11 ...........			1,404,600	15	3,254,595
16	Total assets. Add lines 1 through 15 (must equal line 33)...			53,179,679	16	44,078,460

17	Accounts payable and accrued expenses .....	10,961,782	17	9,220,689
18	Grants payable ...		18
19	Deferred revenue .........	4,636,652	19	4,274,138
20	Tax-exempt bond liabilities .........		20
21	Escrow or custodial account liability. Complete Part IV of Schedule D	837,905	21	433,536
22	Loans and other payables to any current or former officer, director, trustee, key employee, creator or founder, substantial contributor, or 35% controlled entity or family member of any of these persons .........
			22
23	Secured mortgages and notes payable to unrelated third parties ..		23
24	Unsecured notes and loans payable to unrelated third parties ..		24
25	Other liabilities (including federal income tax, payables to related third parties, and other liabilities not included on lines 17 - 24). Complete Part X of Schedule D	13,967,371	25	11,586,600
26	Total liabilities. Add lines 17 through 25..	30,403,710	26	25,514,963

	Organizations that follow FASB ASC 958, check here and complete lines 27, 28, 32, and 33.
27	Net assets without donor restrictions ..........	22,775,969	27	18,563,497
28	Net assets with donor restrictions ...........		28
	Organizations that do not follow FASB ASC 958, check here and complete lines 29 through 33.
29	Capital stock or trust principal, or current funds .....		29
30	Paid-in or capital surplus, or land, building or equipment fund ...		30
31	Retained earnings, endowment, accumulated income, or other funds		31
32	Total net assets or fund balances ...........	22,775,969	32	18,563,497
33	Total liabilities and net assets/fund balances ........	53,179,679	33	44,078,460