TY 2021 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/1099-NEC)
(1) KENNETH E BENTSEN JR...................................................................... PRESIDENT & CEO	40.00 ................. 0.00	X	X		2,593,558	72,249
(2) JOSEPH SEIDEL...................................................................... COO	40.00 ................. 0.00		X		1,166,978	79,560
(3) IRA D HAMMERMAN - EVP...................................................................... & GENERAL COUNSEL (THRU 12/2022)	40.00 ................. 0.00		X		992,138	71,169
(4) DAVID B KRASNER...................................................................... CFO & CAO	40.00 ................. 0.00		X		708,399	81,956
(5) TIMOTHY W CAMERON...................................................................... MANAGING DIRECTOR (THRU 01/2022)	40.00 ................. 0.00			X	632,762	71,361
(6) JAMIE WALL - EXECUTIVE...................................................................... VICE PRESIDENT (THRU 09/2022)	40.00 ................. 0.00		X		653,006	36,292
(7) CHERYL L CRISPEN...................................................................... EXECUTIVE VICE PRESIDENT	40.00 ................. 0.00		X		600,130	63,269
(8) MARK SCHUERMANN...................................................................... MANAGING DIRECTOR (THRU 04/2022)	40.00 ................. 0.00			X	584,040	49,859
(9) ROBERT TOOMEY...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00			X	542,166	83,105
(10) CARTER K MCDOWELL...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00			X	505,676	65,478
(11) KEVIN CARROLL...................................................................... MANAGING DIRECTOR	40.00 ................. 0.00			X	493,637	36,313
(12) SALVATORE CHIARELLI...................................................................... EXECUTIVE VICE PRESIDENT	40.00 ................. 0.00		X		393,526	68,176
(13) JIM REYNOLDS...................................................................... CHAIR	2.00 ................. 0.00	X	X		0	0
(14) KENNETH CELLA...................................................................... CHAIR ELECT	2.00 ................. 0.00	X	X		0	0
(15) LAURA CHEPUCAVAGE...................................................................... VICE CHAIR	2.00 ................. 0.00	X	X		0	0
(16) JAMES WALLIN...................................................................... TREASURER	2.00 ................. 0.00	X	X		0	0
(17) KEVIN BAILEY...................................................................... 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)	(E) Reportable compensation from related organizations (W-2/1099-MISC/1099-NEC)
(18) DALIA BLASS........................................................................ DIRECTOR (AS OF 10/2022)	1.00 .......................0.00	X
(19) LIBBY CANTRILL........................................................................ DIRECTOR (AS OF 10/2022)	1.00 .......................0.00	X
(20) MICHAEL DURBIN........................................................................ DIRECTOR	1.00 .......................0.00	X
(21) MATTHEW ENYEDI........................................................................ DIRECTOR	1.00 .......................0.00	X
(22) MEGAN FLAHERTY........................................................................ DIRECTOR	1.00 .......................0.00	X
(23) SOL GINDI........................................................................ DIRECTOR (AS OF 10/2022)	1.00 .......................0.00	X
(24) GARY HALL........................................................................ DIRECTOR	1.00 .......................0.00	X
(25) ROBERT HAWLEY........................................................................ DIRECTOR	1.00 .......................0.00	X
(26) JEB HENSARLING........................................................................ DIRECTOR	1.00 .......................0.00	X
(27) LISA KIDD HUNT........................................................................ DIRECTOR	1.00 .......................0.00	X
(28) GARY KANE........................................................................ DIRECTOR (AS OF 11/2021)	1.00 .......................0.00	X
(29) JIM KERR........................................................................ DIRECTOR	1.00 .......................0.00	X
(30) MICHAEL KISBER........................................................................ DIRECTOR	1.00 .......................0.00	X
(31) ANDREW KOMAROFF........................................................................ DIRECTOR	1.00 .......................0.00	X
(32) RONALD KRUSZEWSKI........................................................................ DIRECTOR	1.00 .......................0.00	X
(33) DAVID LEFKOWITZ........................................................................ DIRECTOR (AS OF 07/2022)	1.00 .......................0.00	X
(34) CHARLOTTE MCLAUGHLIN........................................................................ DIRECTOR	1.00 .......................0.00	X
(35) THOMAS MERCHANT........................................................................ DIRECTOR	1.00 .......................0.00	X
(36) CRAIG MESSINGER........................................................................ DIRECTOR	1.00 .......................0.00	X
(37) JOE NADREAU........................................................................ DIRECTOR	1.00 .......................0.00	X
(38) THOMAS PLUTA........................................................................ DIRECTOR	1.00 .......................0.00	X
(39) ROBERT POPOWSKI........................................................................ DIRECTOR	1.00 .......................0.00	X
(40) DOUGLAS PREISER........................................................................ DIRECTOR	1.00 .......................0.00	X
(41) JAMIE PRICE........................................................................ DIRECTOR	1.00 .......................0.00	X
(42) SHAWN QUANT........................................................................ DIRECTOR (AS OF 10/2022)	1.00 .......................0.00	X
(43) SAMUEL RAMIREZ JR........................................................................ DIRECTOR	1.00 .......................0.00	X
(44) PAUL REILLY........................................................................ DIRECTOR	1.00 .......................0.00	X
(45) BRENDAN REILLY........................................................................ DIRECTOR	1.00 .......................0.00	X
(46) JOHN FW ROGERS........................................................................ DIRECTOR	1.00 .......................0.00	X
(47) JEFFREY ROSEN........................................................................ DIRECTOR	1.00 .......................0.00	X
(48) CLAIRE SANTANIELLO........................................................................ DIRECTOR	1.00 .......................0.00	X
(49) ANDY SAPERSTEIN........................................................................ DIRECTOR	1.00 .......................0.00	X
(50) PETER SCHNEIDER........................................................................ DIRECTOR	1.00 .......................0.00	X
(51) DEB SCHONEMAN........................................................................ DIRECTOR	1.00 .......................0.00	X
(52) KABIR SETHI........................................................................ DIRECTOR (AS OF 10/2022)	1.00 .......................0.00	X
(53) NOMITA CHOPRA SINGH........................................................................ DIRECTOR	1.00 .......................0.00	X
(54) MARK STEFFENSEN........................................................................ DIRECTOR	1.00 .......................0.00	X
(55) JOSEPH E SWEENEY........................................................................ DIRECTOR	1.00 .......................0.00	X
(56) JOHN TAFT........................................................................ DIRECTOR	1.00 .......................0.00	X
(57) RYAN TAYLOR........................................................................ DIRECTOR	1.00 .......................0.00	X
(58) JOHN VACCARO........................................................................ DIRECTOR (AS OF 10/2022)	1.00 .......................0.00	X
(59) KASHIF ZAFAR........................................................................ DIRECTOR	1.00 .......................0.00	X
(60) SAIMA AHMED - EVP........................................................................ & GENERAL COUNSEL (AS OF 10/2022)	40.00 .......................0.00		X
(61) JOSH WILSUSSEN - EXECUTIVE........................................................................ VICE PRESIDENT (AS OF 10/2022)	40.00 .......................0.00		X

(A) Name and business address	(B) Description of services	(C) Compensation
WASHINGTON COUN ERNST & YOUNG LLP PO BOX 640382 PITTSBURGH,PA152640382	CONSULTING	882,541
HILLTOP PUBLIC SOLUTIONS LLC 3000 K STREET NW SUITE 320 WASHINGTON,DC20007	CONSULTING	390,000
COVINGTON & BURLING LLP ONE CITYCENTER 850 TENTH ST NW WASHINGTON,DC20001	LEGAL	332,684
SIDLEY AUSTIN LLP 1 S DEARBORN FL 12 CHICAGO,IL60603	LEGAL	285,791
ELMENDORF RYAN LLC 1201 NEW YORK AVE NW STE 900 WASHINGTON,DC20005	CONSULTING	180,000
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 10

- TIN:

SCHEDULE C
(Form 990)

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

2021

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.
Round Bullet

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
Round Bullet

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.
Round Bullet

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.

Cat. No. 50084S

Schedule C (Form 990) 2021

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) 2018	(b) 2019	(c) 2020	(d) 2021	(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) 2021

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 ......................................................................

40,472,762

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 .............................................................................................................................

6,520,000

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

1,196,087

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

7,716,087

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

7,285,097

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? ......................................................................................................................

430,990

Taxable amount of lobbying and political expenditures. See Instructions .........................................

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) 2021

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

2021

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) 2021

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	6,199,173	613,890	5,585,283
d	Equipment ....	3,586,635	1,452,962	2,133,673
e	Other .....
Total. Add lines 1a through 1e. (Column (d) must equal Form 990, Part X, column (B), line 10(c).)..				7,718,956

Schedule D (Form 990) 2021

Page 3

Part VII

Investments - Other 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
(A)
(B)
(C)
(D)
(E)
(F)
(G)
(H)
Total. (Column (b) must equal Form 990, Part X, col. (B) line 12.)

Part VIII

Investments - Program 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

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
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)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
Total. (Column (b) must equal Form 990, Part X, col.(B) line 15.)...........

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.)	12,119,447
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) 2021

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	53,261,800
2	Amounts included on line 1 but not on Form 990, Part VIII, line 12:
a	Net unrealized gains (losses) on investments ....	2a	-1,506,820
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	-1,506,820
3	Subtract line 2e from line 1..................			3	54,768,620
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	54,768,620

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	51,359,676
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	-1,995,277
e	Add lines 2a through 2d....................			2e	-1,995,277
3	Subtract line 2e from line 1...................			3	53,354,953
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	53,354,953

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 2022, THE SYNDICATED FUNDS COLLECTED FROM MEMBERS AND DISBURSED FOR SUCH SPECIAL PROJECTS TOTALED $1,564,308 AND $1,714,297 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:	NET PERIODIC POST RETIREMENT BENEFIT COST -1,995,277.

Schedule D (Form 990) 2021

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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

2021

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 1214A INGLESIDE AVENUE MCLEAN,VA22101	27-2429741	501(C)(4)	30,000	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 901 WASHINGTON,DC20005	54-0883744	501(C)(3)	8,000	PROGRAM SUPPORT
(4) HERITAGE ACTION FOR AMERICA 214 MASSACHUSETTS AVENUE NE WASHINGTON,DC20002	27-2244700	501(C)(4)	25,000	PROGRAM SUPPORT
(5) NATIONAL ADULT PROTECTIVE SERVICES ASSOCIATION 1612 K STREET NW SUITE 200 WASHINGTON,DC20090	30-0044497	501(C)(3)	18,000	PROGRAM SUPPORT
(6) NCSL FOUNDATION FOR STATE LEGISLATURES 7700 EAST FIRST PLACE DENVER,CO80230	74-2232576	501(C)(3)	10,000	PROGRAM SUPPORT
(7) PHOENIX CHILDREN'S PROJECT 3219 E CAMELBACK ROAD 228 PHOENIX,AZ85018	90-0137202	501(C)(3)	8,900	CONFERENCE SPONSOR FUNDED SUPPORT
(8) PREVENT CANCER FOUNDATION 333 JOHN CARLYLE STREET SUITE 635 ALEXANDRIA,VA22314	52-1429544	501(C)(3)	10,000	PROGRAM SUPPORT
(9) PROGRAM ON INTERNATIONAL FINANCIAL SYSTEM INC 134 MOUNT AUBURN ST CAMBRIDGE,MA02138	82-2586755	501(C)(3)	7,500	PROGRAM SUPPORT
(10) SEC HISTORICAL SOCIETY 1101 PENNSYLVANIA AVENUE NW STE 300 WASHINGTON,DC20004	52-2213646	501(C)(3)	10,000	PROGRAM SUPPORT
(11) WASHINGTON TENNIS & EDUCATION FOUNDATION 16TH AND KENNEDY STREET NW WASHINGTON,DC20011	52-6046504	501(C)(3)	7,500	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) 2021

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) 2021

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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

2021

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? .........

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) 2021

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, 1099-MISC compensation, and/or 1099-NEC			(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)	1,488,014 ------------- 0	1,100,000 ------------- 0	5,544 ------------- 0	34,800 ------------- 0	37,449 ------------- 0	2,665,807 ------------- 0	0 ------------- 0
2JOSEPH SEIDEL COO	(i) (ii)	687,622 ------------- 0	475,000 ------------- 0	4,356 ------------- 0	34,800 ------------- 0	44,760 ------------- 0	1,246,538 ------------- 0	0 ------------- 0
3IRA D HAMMERMAN - EVP & GENERAL COUNSEL (THRU 12/2022)	(i) (ii)	579,094 ------------- 0	407,500 ------------- 0	5,544 ------------- 0	34,800 ------------- 0	36,369 ------------- 0	1,063,307 ------------- 0	0 ------------- 0
4DAVID B KRASNER CFO & CAO	(i) (ii)	394,787 ------------- 0	310,000 ------------- 0	3,612 ------------- 0	34,800 ------------- 0	47,156 ------------- 0	790,355 ------------- 0	0 ------------- 0
5TIMOTHY W CAMERON MANAGING DIRECTOR (THRU 01/2022)	(i) (ii)	432,094 ------------- 0	190,000 ------------- 0	10,668 ------------- 0	34,800 ------------- 0	36,561 ------------- 0	704,123 ------------- 0	0 ------------- 0
6JAMIE WALL - EXECUTIVE VICE PRESIDENT (THRU 09/2022)	(i) (ii)	452,437 ------------- 0	200,000 ------------- 0	569 ------------- 0	34,800 ------------- 0	1,492 ------------- 0	689,298 ------------- 0	0 ------------- 0
7CHERYL L CRISPEN EXECUTIVE VICE PRESIDENT	(i) (ii)	354,018 ------------- 0	242,500 ------------- 0	3,612 ------------- 0	34,800 ------------- 0	28,469 ------------- 0	663,399 ------------- 0	0 ------------- 0
8MARK SCHUERMANN MANAGING DIRECTOR (THRU 04/2022)	(i) (ii)	461,202 ------------- 0	120,000 ------------- 0	2,838 ------------- 0	34,800 ------------- 0	15,059 ------------- 0	633,899 ------------- 0	0 ------------- 0
9ROBERT TOOMEY MANAGING DIRECTOR	(i) (ii)	376,622 ------------- 0	160,000 ------------- 0	5,544 ------------- 0	37,344 ------------- 0	45,761 ------------- 0	625,271 ------------- 0	0 ------------- 0
10CARTER K MCDOWELL MANAGING DIRECTOR	(i) (ii)	415,132 ------------- 0	85,000 ------------- 0	5,544 ------------- 0	34,800 ------------- 0	30,678 ------------- 0	571,154 ------------- 0	0 ------------- 0
11KEVIN CARROLL MANAGING DIRECTOR	(i) (ii)	347,025 ------------- 0	143,000 ------------- 0	3,612 ------------- 0	34,800 ------------- 0	1,513 ------------- 0	529,950 ------------- 0	0 ------------- 0
12SALVATORE CHIARELLI EXECUTIVE VICE PRESIDENT	(i) (ii)	226,594 ------------- 0	165,000 ------------- 0	1,932 ------------- 0	34,800 ------------- 0	33,376 ------------- 0	461,702 ------------- 0	0 ------------- 0

Schedule J (Form 990) 2021

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.

Schedule J (Form 990) 2021

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SCHEDULE O
(Form 990)

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

2021

Open to Public
Inspection

Name of the organization

SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION

Employer identification number

32-0178959

Return Reference	Explanation
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: WWW.SIFMA.ORG/BCP FINANCIAL SERVICES IS A CRITICAL INFRASTRUCTURE SECTOR AS IDENTIFIED BY THE U.S. DEPARTMENT OF HOMELAND SECURITY. SIFMA AND ITS MEMBER FIRMS ARE DEDICATED TO PREPARING FOR THE RISK OF POTENTIAL DISRUPTIONS AT BOTH THE FIRM AND BROADER INDUSTRY LEVELS. SIFMA PLAYS A KEY ROLE IN COORDINATING THE INDUSTRY'S RESPONSE TO INCIDENTS THAT CAN INTERRUPT BUSINESS AND MARKET FUNCTIONS AND WORKS TO SUPPORT FIRM-LEVEL BCP PLANNING AS WELL. INDUSTRY-WIDE BUSINESS CONTINUITY TEST: WWW.SIFMA.ORG/BCP-TEST THE INDUSTRY-WIDE BUSINESS CONTINUITY TEST IS A CRITICAL EXERCISE THAT HIGHLIGHTS OUR INDUSTRY'S ABILITY TO OPERATE THROUGH A SIGNIFICANT EMERGENCY USING BACKUP SITES, RECOVERY FACILITIES AND BACKUP COMMUNICATIONS CAPABILITIES ACROSS THE INDUSTRY. THE TEST IS SUPPORTED BY ALL MAJOR EXCHANGES, MARKETS AND INDUSTRY UTILITIES. IT INVOLVES TEST TRANSACTIONS FOR COMMERCIAL PAPER, EQUITIES, OPTIONS, FUTURES, FIXED INCOME, SETTLEMENT, PAYMENTS, TREASURY AUCTIONS AND MARKET DATA. SIFMA ALSO FACILITATES A COORDINATED REG SCI TESTING PROGRAM WHICH IS COMPLETED IN PARALLEL WITH THE SIFMA INDUSTRY TEST. THE TEST OCCURS ON THE SAME DAY AS FUTURES MARKET TESTING COORDINATED BY THE FUTURES INDUSTRY ASSOCIATION (FIA), AND ON ALTERNATE YEARS WITH CANADIAN MARKET PARTICIPANT TEST THROUGH THE INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA (IIROC). EMERGENCY CRISIS MANAGEMENT COMMAND CENTER: WWW.SIFMA.ORG/EMERGENCY IN THE EVENT OF AN INDUSTRY-WIDE INCIDENT, SIFMA CONVENES MARKET PARTICIPANTS; ISSUES MARKET CLOSE RECOMMENDATIONS; AND COORDINATES WITH MARKET INFRASTRUCTURE PROVIDERS, REGULATORS AND EMERGENCY PERSONNEL INCLUDING THE U.S. DEPARTMENT OF THE TREASURY, U.S. DEPARTMENT OF HOMELAND SECURITY, NEW YORK CITY OFFICE OF EMERGENCY MANAGEMENT, LAW ENFORCEMENT AND OTHER OFFICIAL SECTOR PARTICIPANTS. SIFMA ORGANIZES MARKET RESPONSE COMMITTEES FOR THE FIXED INCOME AND EQUITY MARKETS TO DELIVER AN INDUSTRY PERSPECTIVE IN THE EVENT OF DISRUPTIONS TO MARKET INFRASTRUCTURE WHICH MAY MAKE UNSCHEDULED MARKET CLOSES OR CHANGES TO SETTLEMENT CONVENTION NECESSARY. THE COMMITTEES HAVE DEVELOPED PRINCIPLES AND OBJECTIVE DECISION-MAKING PROCESSES THAT RECOGNIZE THE SIGNIFICANT IMPROVEMENTS THE INDUSTRY HAS MADE WITH RESPECT TO BUSINESS CONTINUITY AND THE EXPECTATIONS OF REGULATORS. THESE PRINCIPLES ALSO REFLECT EXPECTATIONS FOR STRONG RESILIENCY PLANS OF CRITICAL FINANCIAL MARKET INFRASTRUCTURE AND FINANCIAL INSTITUTIONS. FOR FIXED INCOME, THE COMMITTEE HAS DEVELOPED PROCEDURES TO DETERMINE IF IT IS NECESSARY FOR SIFMA TO RECOMMEND AN UNSCHEDULED CLOSE IN U.S. FIXED INCOME MARKETS. CYBERSECURITY: WWW.SIFMA.ORG/CYBERSECURITY CYBERATTACKS HAVE BECOME MORE BOLD AND THE THREAT HIGHER. HOWEVER, INDUSTRY-WIDE EFFORTS OVER THE LAST DECADE HAVE ALSO EVOLVED AND GROWN TO BUILD EFFECTIVE CYBER DEFENSES. SIFMA IS ACTIVELY ENGAGED IN COORDINATING THE EFFORT TO SUPPORT A SAFE, SECURE INFORMATION INFRASTRUCTURE, WITH CYBERSECURITY RESOURCES INCLUDING BEST PRACTICES FOR INSIDER THREATS, DATA PROTECTION PRINCIPLES, FRAMEWORKS FOR PENETRATION TESTING AND MORE THAT PROVIDE SECURITY OF CUSTOMER INFORMATION AND EFFICIENT, RELIABLE EXECUTION OF TRANSACTIONS. WE CONTINUALLY WORK 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. SIFMA'S CYBER-RESILIENCY EFFORTS SEEK TO: - PROMOTE ENHANCED REGULATORY HARMONIZATION TO ENCOURAGE A MORE EFFECTIVE ALLOCATION OF CYBER RESOURCES; - PROMOTE A ROBUST INDUSTRY-GOVERNMENT PARTNERSHIP GROUNDED IN INFORMATION SHARING; - DESIGN EXERCISES AND INDUSTRY TESTS TO IMPROVE PROTOCOLS FOR INCIDENT PREPAREDNESS, RESPONSE AND RECOVERY; AND - USE THE LESSONS LEARNED TO REFINE INDUSTRY BEST PRACTICES, INCLUDING FOR MANAGING INSIDER THREATS, THIRD PARTY RISK; PENETRATION TESTING AND DATA SECURITY, INCLUDING SECURE DATA STORAGE AND RECOVERY. SHORTENED SETTLEMENT CYCLES: WWW.SIFMA.ORG/EXPLORE-ISSUES/SHORTENING-SETTLEMENT-CYCLE ENHANCING OUR SECURITIES SETTLEMENT PROCESS IS CRITICAL TO THE CONTINUED RESILIENCY OF OUR MARKETS AND MARKET OPERATIONS. IN THE U.S., THE STANDARD SETTLEMENT CYCLE FOR EQUITIES AND OTHER PRODUCTS IS T+2 (TWO BUSINESS DAYS AFTER THE TRADE). FOLLOWING THE INDUSTRY'S SUCCESSFUL WORK TO TRANSITION FROM T+3 TO T+2 IN 2017, SIFMA, THE INVESTMENT COMPANY INSTITUTE (ICI), AND THE DEPOSITORY TRUST & CLEARING CORPORATION (DTCC) ARE NOW COLLABORATING TO ACCELERATE THE U.S. SECURITIES SETTLEMENT CYCLE FROM T+2 TO T+1, WHICH SHOULD BE COMPLETED IN THE THIRD QUARTER OF 2024, PENDING REGULATORY SUPPORT. WHY THIS MASSIVE UNDERTAKING? T+1 SETTLEMENT CYCLE WILL MITIGATE SETTLEMENT RISK WELL BEYOND WHAT WAS ACHIEVED UNDER T+2. IN ADDITION, A MOVE TO T+1 WILL INCREASE SETTLEMENT EFFICIENCIES AND IMPROVE THE USE OF CAPITAL, ESPECIALLY IN PERIODS OF HIGH VOLATILITY. TAKING 24 HOURS OUT OF THE SETTLEMENT CYCLE WILL REQUIRE A MYRIAD OF SIGNIFICANT CHANGES. THE LIST OF IMPACTED AREAS IS LONG: GLOBAL SETTLEMENTS, DOCUMENTATION, CORPORATE ACTIONS, SECURITIES ISSUANCE, AND COORDINATION FOR MUTUAL FUND PORTFOLIO SECURITIES AND INVESTOR SHARES. SOME AREASALLOCATIONS, AFFIRMATION AND DISAFFIRMATION PROCESSES, CLEARINGHOUSE PROCESS TIMELINES, AND SECURITIES LENDINGWILL REQUIRE FUNDAMENTAL CHANGES. OTHER AREAS THAT WILL REQUIRE SIGNIFICANT CHANGE INCLUDE PRIME BROKERAGE, DELIVERY OF INVESTOR DOCUMENTATION, FOREIGN CURRENCY EXCHANGE (FX), GLOBAL MOVEMENT OF SECURITIES AND CURRENCY, BATCH CYCLE TIMING, AND EXCHANGE-TRADED FUND (ETF) CREATION AND REDEMPTION. IT WILL ALSO BE IMPERATIVE TO ANALYZE CURRENT SETTLEMENTS TO IDENTIFY THE REASONS BEHIND SETTLEMENT ERRORS AND FAILS AND ENSURE THAT THE ERROR AND FAIL RATES DO NOT INCREASE UNDER A NEWLY COMPRESSED TIMELINE. TO ASSIST MARKET PARTICIPANTS IN THE MOVE TO T+1, SIFMA, THE INVESTMENT COMPANY INSTITUTE (ICI), AND THE DEPOSITORY TRUST & CLEARING CORPORATION (DTCC), TOGETHER WITH DELOITTE LLP (DELOITTE), HAVE PUBLISHED THE T+1 SECURITIES SETTLEMENT INDUSTRY IMPLEMENTATION PLAYBOOK. THIS GUIDE OUTLINES A DETAILED APPROACH TO IDENTIFYING THE IMPLEMENTATION ACTIVITIES, TIMELINES, DEPENDENCIES, AND RISK IMPACTS THAT MARKET PARTICIPANTS SHOULD CONSIDER AS THEY PREPARE FOR THE TRANSITION TO T+1 SETTLEMENT.
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. EQUITY MARKET STRUCTURE: WWW.SIFMA.ORG/EXPLORE-ISSUES/EQUITY-MARKET-STRUCTURE THE U.S. EQUITY MARKETS ARE THE MOST ROBUST IN THE WORLD AND CONTINUE TO BE AMONG THE DEEPEST, MOST COMPETITIVE, MOST LIQUID AND MOST EFFICIENT. THEY ARE ALSO AMONG THE MOST REGULATED. EFFICIENT AND RESILIENT MARKET STRUCTURE IS KEY TO SUSTAINING INVESTOR CONFIDENCE AND PARTICIPATION IN THE EQUITY MARKETS. MARKET STRUCTURE CAN DRIVE LIQUIDITY AND TRADE COSTS FOR BUSINESSES AND INVESTORS ALIKE. THEREFORE, MARKET PARTICIPANTS CONTINUALLY STRIVE TO CREATE THE MOST EFFICIENT MARKETS. THIS INCLUDES ADAPTING NEW TECHNOLOGIES TO ACHIEVE OPERATIONAL EFFICIENCIES, SEARCHING FOR NEW WAYS TO TRANSACT AND, GENERALLY, OPTIMIZING MARKET STRUCTURE TO MAXIMIZE EFFICIENCIES. MARKET MAKERS EXIST TO PROVIDE LIQUIDITY IN SECURITIES AND EXECUTE CUSTOMER TRADES, PLAYING AN IMPORTANT ROLE IN EQUITY MARKET STRUCTURE BY ENABLING LIQUIDITY AND BALANCING BUY AND SELL DEMAND. IMPORTANTLY, INVESTORS, PARTICULARLY RETAIL INVESTORS, BENEFIT FROM THIS EFFICIENCY AND RESILIENCY THROUGH REDUCED COSTS INCLUDING NO OR LOW COMMISSIONS, BEST EXECUTION AND COMPETITION. ALL MARKET PARTICIPANTS SEEK TO DRIVE INNOVATION TO FURTHER IMPROVE EQUITY MARKET EFFICIENCY, RESILIENCY AND MOST IMPORTANTLY THE BENEFIT TO INVESTORS. HOWEVER, REGULATORS MUST CAREFULLY WEIGH THE IMPACT OF ANY CHANGES ON INVESTORS. SPECIFICALLY, AS THE SEC CONSIDERS PROPOSING MAJOR CHANGES TO OUR CURRENT EQUITY MARKET STRUCTURE SYSTEM, IT IS CRITICAL THAT ANY CHANGES BE DATA DRIVEN WITH ROBUST COST BENEFIT ANALYSIS. IN THE END, REGULATORS AND MARKET PARTICIPANTS SHOULD WORK TOWARDS THE SAME GOAL: TO PROMOTE MARKET RESILIENCY AND EFFICIENCY AND ENSURE THE U.S. EQUITY MARKETS CONTINUE TO BENEFIT INVESTORS AND PLAY AN ESSENTIAL ROLE IN CAPITAL FORMATION. FIXED INCOME MARKET STRUCTURE: WWW.SIFMA.ORG/EXPLORE-ISSUES/FIXED-INCOME-MARKET-STRUCTURE FIXED INCOME MARKETS ARE AN INTEGRAL COMPONENT TO ECONOMIC GROWTH, PROVIDING EFFICIENT, LONG- TERM AND COST-EFFECTIVE FUNDING. HOW MARKET LIQUIDITY CAN BE MAINTAINED, INCLUDING FOR CORPORATE BONDS, MUNICIPAL BONDS, MORTGAGE-BACKED SECURITIES, AND TREASURY SECURITIES, IS THE SUBJECT OF SIGNIFICANT STUDY AND DEBATE KEY ISSUES CURRENTLY FACING THE FIXED INCOME MARKETS INCLUDE THE APPLICATION OF RULE 15C2-11 TO THE FIXED INCOME MARKETS, INVESTING IN INFRASTRUCTURE THROUGH MUNICIPAL FINANCE, AND AMENDMENTS TO REGULATION ATS AS THEY RELATE TO GOVERNMENT SECURITIES. THE U.S. TREASURY MARKET IS A BEDROCK OF THE GLOBAL FINANCIAL SYSTEM. U.S. TREASURIES ARE DEBT INSTRUMENTS ISSUED BY THE U.S. GOVERNMENT TO FINANCE ITS ACTIVITIES. OWING TO THE UNITED STATES' CREDITWORTHINESS AND STATUS AS THE WORLD'S LEADING ECONOMY, THE U.S. TREASURY MARKET HAS BEEN DESCRIBED AS THE "BIGGEST, DEEPEST AND MOST ESSENTIAL BOND MARKET ON THE PLANET." OWING TO THEIR STABILITY, U.S. TREASURIES ALSO OFTEN SERVE AS BENCHMARKS FOR OTHER FIXED-INCOME SECURITIES AND HEDGING POSITIONS; AS A RESULT, U.S. TREASURY YIELDS HAVE AN IMPACT ON THE RATES THAT CONSUMERS, BUSINESSES, AND GOVERNMENTS ACROSS THE GLOBE PAY TO BORROW MONEY. IN ADDITION, THE U.S. TREASURY REPURCHASE AGREEMENT OR "REPO" MARKET IS A KEY TRANSMISSION MECHANISM FOR U.S. MONETARY POLICY, AND VITAL TO THE LIQUIDITY OF THE CASH TREASURY MARKET. RECENT STUDIES TO IMPROVE THE RESILIENCY OF THE TREASURY MARKET: 1. GREATER USE OF CENTRALIZED CLEARING AND "ALL-TO-ALL" TRADING PLATFORMS; 2. UNIFORM REGULATION AND OVERSIGHT OF MARKET PARTICIPANTS; 3. EXPANDED ACCESS TO THE FEDERAL RESERVE'S RECENTLY CREATED STANDING REPURCHASE ("REPO" FACILITY ("SRF"); 4. CHANGES TO BANKING REGULATION (SUCH AS REFORM OF THE SLR REQUIREMENT); AND 5. IMPROVED DATA AND DISCLOSURE BY MARKET PARTICIPANTS. SOME OF THE REFORMS APPEAR ABLE TO ADD MORE STRAIGHTFORWARDLY TO MARKET MAKING CAPACITY; FOR EXAMPLE, MODIFICATIONS TO THE SUPPLEMENTAL LEVERAGE RATIO (SLR) AND GSIB SURCHARGE COULD BE RELATIVELY STRAIGHTFORWARD AND RESULT IN MORE CAPACITY AT SIGNIFICANT MARKET PARTICIPANTS. ON THE OTHER HAND, MANDATING BROAD CENTRAL CLEARING IN THE CASH MARKET, WHILE DELIVERING SOME BENEFITS, COULD RAISE COSTS AND LIMIT PARTICIPATION BY SOME. THE GOALS OF ANY REFORMS IN THE TREASURY MARKET SHOULD BE TO ENHANCE THE LIQUIDITY AND RESILIENCY IN THE MARKET AND TO INCREASE THE MARKET-MAKING CAPACITY OF MARKET PARTICIPANTS IN ORDER TO MEET THE GROWING DEMAND FOR, AND SUPPLY OF, TREASURY SECURITIES. THESE TWIN GOALS MUST BE TOP-OF-MIND AS POLICYMAKERS AND MARKET PARTICIPANTS ASSESS THE COSTS AND BENEFITS OF ANY REFORMS. MARKET INNOVATION AND DIGITAL ASSETS: WWW.SIFMA.ORG/EXPLORE-ISSUES/DIGITIZATION 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. FINANCIAL SERVICES FIRMS ARE EMBRACING THE CLOUD AND DISTRIBUTED LEDGER TECHNOLOGY (DLT) TO TRANSFORM THE CAPITAL MARKET ECOSYSTEM AND INFRASTRUCTURE. IN WEALTH MANAGEMENT, NEW CAPABILITIES ARE ANTICIPATING CUSTOMER EXPECTATIONS AND BETTER SERVING CLIENTS AS THEY DEMAND A MORE PERSONAL, IMMEDIATE EXPERIENCE WHILE THE FINANCIAL INDUSTRY REMAINS COMMITTED TO ENSURING PROTECTING THE DATA OF THE CLIENTS WE SERVE AT EVERY TURN. AND, AS THE INDUSTRY MOVES TOWARD FURTHER SHORTENING THE SETTLEMENT CYCLE, E-DELIVERY WILL ONLY BECOME MORE NECESSARY, AND WE ARE ENGAGING WITH THE SEC TO MAKE IT EASIER FOR MARKET PARTICIPANTS TO MAKE THIS TRANSITION. PERHAPS THE MOST DISCUSSED AREA OF DEVELOPMENT, HOWEVER, IS DIGITAL ASSETS. WE ARE AT A PIVOTAL POINT IN THE DEVELOPMENT OF DIGITAL ASSETS MARKETS AND PRODUCTS, INCLUDING BLOCKCHAIN-BASED SECURITIES, STABLE COINS AND CRYPTO ASSETS. THERE IS AN URGENT NEED FOR POLICYMAKERS TO PROVIDE REGULATORY CLARITY TO THE DIGITAL ASSET MARKETS. THE EXISTING REGULATORY FRAMEWORKS WHICH GOVERN REGULATED FINANCIAL INSTITUTIONS SUCH AS BROKER-DEALERS, BANKS AND ASSET MANAGERS ARE FOCUSED ON ENSURING INVESTOR PROTECTION, SAFETY AND SOUNDNESS, AND RISK MANAGEMENT, AND EXTENDING THEM, WITH MODIFICATIONS WHERE APPROPRIATE, TO DIGITAL ASSET MARKETS WILL HELP PROTECT INVESTORS. SIFMA HAS CALLED ON POLICYMAKERS AND REGULATORS PURSUE KEY GUIDING PRINCIPLES AS THEY MAKE POLICY IN THIS AREA. THESE INCLUDE PUTTING INVESTOR PROTECTIONS AT THE FOREFRONT OF ANY POLICY ACTION; ADOPTING A "TECHNOLOGY NEUTRAL" APPROACH THAT FOLLOWS THE "SAME RISK, SAME ACTIVITY, SAME REGULATORY OUTCOME" PRINCIPLE; DISTINGUISHING BETWEEN DIFFERENT TYPES OF DIGITAL ASSETS, AND BETWEEN DIGITAL ASSETS AND THE USE OF BLOCKCHAIN TECHNOLOGY TO FACILITATE "TRADITIONAL" ASSET TRANSACTIONS; AND APPLYING, WITH APPROPRIATE MODIFICATIONS, EXISTING AND WELL UNDERSTOOD REGULATORY FRAMEWORKS TO DIGITAL ASSETS. AS DESCRIBED, EXISTING SECURITIES REGULATION, SUCH AS THE SEC'S CUSTOMER PROTECTION RULE, OFFERS A ROBUST FRAMEWORK FOR INVESTOR PROTECTION WHICH CAN BE APPLIED TO DIGITAL ASSET MARKETS. RETIREMENT & SAVINGS: WWW.SIFMA.ORG/EXPLORE-ISSUES/RETIREMENT-SAVINGS HELPING AMERICANS GROW SAVINGS FOR A SECURE RETIREMENT IS AMONG THE MOST IMPORTANT ROLES OF THE U.S. CAPITAL MARKETS. INDIVIDUALS OF ALL INCOME LEVELS CAN START INVESTING, INVEST FOR THE LONG-TERM, AND HAVE ACCESS TO WORK WITH A PROFESSIONAL FINANCIAL ADVISOR WHO SERVES AS A CRITICAL LINK IN HELPING INVESTORS MEET THEIR GOALS. CHANGING DEMOGRAPHICS, INCLUDING INCREASING LONGEVITY, UNDERSCORE THE NEED FOR A ROBUST PRIVATE RETIREMENT SYSTEM. POLICY MAKERS MUST CONTINUE TO ADDRESS THE CHALLENGE OF ENCOURAGING AND FACILITATING SAVING AND INVESTING FOR RETIREMENT ACROSS OUR SOCIETY. TODAY, U.S. WORKERS ARE INCREASINGLY RELYING ON INDIVIDUALLY FUNDED RETIREMENT PLANS, SUCH AS 401K'S AND IRA'S. DEFINED CONTRIBUTION PLANS ACCOUNT FOR $7.4 TRILLION IN ASSETS, GROWING AT A 7% COMPOUND ANNUAL GROWTH RATE OVER THE LAST DECADE. BOTH THROUGH THEIR EMPLOYERS AND INDIVIDUALLY, AMERICANS TODAY ARE LARGELY RESPONSIBLE FOR BUILDING THEIR RETIREMENT ACCOUNTS THEMSELVES. OVER 56% OF TOTAL RETIREMENT ASSETS ARE INDIVIDUALLY FUNDED THROUGH DEFINED CONTRIBUTION RETIREMENT PLANS AND IRAS. BECAUSE INDIVIDUAL SAVERS PLAY A GREATER ROLE IN THE DECISION-MAKING
FORM 990, PART III, LINE 4B	REGARDING THEIR INVESTMENTS, ACCESS TO A FINANCIAL ADVISOR IS EVEN MORE IMPORTANT TODAY TO HELP INDIVIDUALS PREPARE FOR THEIR FUTURE. SIFMA IS COMMITTED TO INCREASING RETIREMENT SECURITY FOR ALL AMERICANS AND HAS IDENTIFIED THREE PRIMARY PILLARS TO REACH THIS GOAL: 1. EXPANDING ACCESS TO PLANS, 2. INCREASING PARTICIPATION AND DECREASING LEAKAGE, AND 3. ENHANCING EDUCATION. SIFMA SUPPORTS LEGISLATION INCLUDING THE SECURING A STRONG RETIREMENT ACT OF 2021 (SECURE ACT 2.0) AND THE RETIREMENT SECURITY AND SAVINGS ACT OF 2021, COMPARABLE BILLS WHICH REPRESENT IMPORTANT STEPS TOWARD ENHANCING THE PRIVATE RETIREMENT SYSTEM AND INCREASING RETIREMENT SAVINGS. BOTH INCLUDE PROVISIONS TO INCENTIVIZE SMALL BUSINESS TO OFFER RETIREMENT PLANS, EXPANDING SMALL BUSINESS SAVINGS; ENABLE OLDER AMERICANS TO SAVE MORE AND HOLD ON TO THEIR SAVINGS LONGER; AND ALLOW MATCHING CONTRIBUTIONS FOR STUDENT LOAN PAYMENTS. WITH EFFORTS SUCH AS THESE, WE CAN BOOST PARTICIPATION IN RETIREMENT SAVINGS, ENABLE AMERICANS TO SAVE MORE, PROMOTE FINANCIAL LITERACY AND SUPPORT A STRONG RETAIL INVESTOR CULTURE. PRUDENTIAL REGULATION OF CAPITAL MARKETS: WWW.SIFMA.ORG/EXPLORE-ISSUES/PRUDENTIAL-REGULATION 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 PRUDENTIAL REGULATORY REGIME ACCOUNTS FOR THE VITAL ROLE THE CAPITAL MARKETS PLAY IN PROVIDING CREDIT AND FINANCING THE REAL ECONOMY, PARTICULARLY AS REGULATORS CONSIDER THE IMPLEMENTATION OF ELEMENTS OF THE BASEL III CAPITAL PROPOSAL, INCLUDING THE FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) AND CREDIT VALUATION ADJUSTMENT (CVA). THOSE RULES SHOULD BE IMPLEMENTED IN A MANNER THAT DOES NOT PENALIZE BANKS' CAPITAL MARKETS ACTIVITIES, WHICH IN TURN COULD REDUCE LIQUIDITY IN VITAL CORPORATE AND OTHER FUNDING MARKETS, THEREBY HURTING GROWTH IN THE REAL ECONOMY. 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 A SUPERVISOR OF THE CAPITAL MARKETS AT TIMES 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. IT IS THUS CRUCIAL TO ALIGN AND ALLOW FOR MUTUAL RECOGNITION, TO THE EXTENT POSSIBLE, THE CAPITAL AND LIQUIDITY STANDARDS SET OUT BY THE U.S. BANKING REGULATORS AND THE MARKET REGULATORS. FOSTERING DIVERSITY, EQUITY & INCLUSION: WWW.SIFMA.ORG/DIVERSITY DIVERSITY, EQUITY AND INCLUSION IS AN ISSUE OF UTMOST IMPORTANCE FOR THE FINANCIAL SERVICES INDUSTRY AND SOCIETY AT LARGE. OUR INDUSTRY LEADERS, TOGETHER WITH REGULATORS AND CORPORATE STAKEHOLDERS, PLAY A PIVOTAL ROLE IN SHAPING ORGANIZATIONAL CULTURE TO ACHIEVE A MORE INCLUSIVE AND EFFECTIVE WORKFORCE THAT REFLECTS THOSE WE SERVE. SIFMA ADVOCATES FOR A DIVERSE, EQUITABLE AND INCLUSIVE FINANCIAL INDUSTRY. TOGETHER WITH OUR MEMBERS, WE 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. FOR MORE THAN 20 YEARS, THE COUNCIL HAS CONDUCTED A BENCHMARK SURVEY AND ENCOURAGES MORE OF OUR MEMBER FIRMS TO PARTICIPATE. WHILE CLEARLY AN ONGOING COMMITMENT FOR THE INDUSTRY, HAVING CONVERSATIONS AND WORKING TOWARDS A MORE DIVERSE, EQUITABLE, AND INCLUSIVE FUTURE IS IMPERATIVE. SIFMA'S BENCHMARK SURVEY PROVIDES PARTICIPANTS WITH CRITICAL INSIGHTS FOR FIRMS TO TAKE ACTION. ON THE WHOLE, OUR 2022 SURVEY FOUND SIGNIFICANT PROGRESS MADE IN HIRING WOMEN AND PEOPLE OF COLOR AND EFFORTS TO BUILD INCLUSIVE CULTURES, SUCH AS EXECUTIVE SPONSORSHIP AND EMPLOYEE RESOURCE GROUPS. THE LEVERS THE INDUSTRY NEEDS TO ADDRESS NOW? PROMOTING FEMALE EMPLOYEES TO EXECUTIVE RANKS AND RETENTION OF ETHNICALLY DIVERSE TALENT. BY BUILDING A DIVERSE TALENT PIPELINE, WE CAN FOSTER DIVERSITY, EQUITY AND INCLUSION IN THE FINANCIAL SERVICES INDUSTRY. THE SIFMA INVEST! PROGRAM AND VIRTUAL PLATFORM OFFERS STUDENTS ENROLLED AT HISTORICALLY BLACK COLLEGES AND UNIVERSITIES (HBCUS) AND MINORITY SERVING INSTITUTIONS (MSIS) A MYRIAD OF EDUCATIONAL, INDUSTRY RESEARCH AND CAREER DEVELOPMENT OPPORTUNITIES TO PURSUE A CAREER IN FINANCIAL SERVICES. AT A GLANCE, SIFMA INVEST! PROVIDES: - A JOB BOARD OF INTERNSHIP AND ENTRY-LEVEL OPPORTUNITIES PROVIDED BY SIFMA'S MEMBER FIRMS; - A RESUME BANK SEARCHABLE BY RECRUITERS FROM SIFMA'S MEMBER FIRMS; - EDUCATIONAL RESOURCES ABOUT THE CAPITAL MARKETS AND CAREERS IN FINANCIAL SERVICES; AND - OPPORTUNITIES FOR STUDENTS TO STUDY FOR AND TAKE THE FINRA SECURITIES INDUSTRY ESSENTIALS (SIE) EXAM.
FORM 990, PART III, LINE 4B	(1) SECURE THE PASSAGE OF LEGISLATION PERMITTING ISSUERS TO ADVANCE REFUND THEIR MUNICIPAL DEBT ON A TAX-EXEMPT MUNICIPAL BASIS; (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. HELPING BUSINESSES AND INVESTORS MANAGE RISK: DERIVATIVES ARE AN IMPORTANT TOOL THAT BUSINESSES AND INVESTORS USE TO MANAGE RISK EXPOSURE. 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. SIFMA BELIEVES THAT THE DODD-FRANK ACT TOOK SEVERAL IMPORTANT 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. IN OCTOBER 2021, AN IMPORTANT STEP WAS ACHIEVED WHEN THE SEC'S SECURITY-BASED SWAP DEALER (SBSD) REGIME WENT LIVE AND THE FIRST SBSD REGISTRATIONS WERE REPORTED SOON THEREAFTER. SIFMA WILL CONTINUE TO ENGAGE CLOSELY WITH THE SEC AS IT WORKS TO COMPLETE TITLE VII RULEMAKING IN 2022. LOOKING FORWARD, POLICYMAKERS SHOULD CONTINUE TO HARMONIZE REGULATIONS BETWEEN THE SEC AND CFTC; AVOID OVERLY BROAD APPLICATION OF TITLE VII IN CROSS-BORDER SITUATIONS, INCLUDING EXPANDING THE AVAILABILITY OF BILATERAL REGULATORY RECOGNITION (SUBSTITUTED COMPLIANCE); AND CONTINUOUSLY REVIEW AND EVALUATE THE IMPACT OF REGULATIONS ON THE SWAP MARKETS AND MARKET PARTICIPANTS, INCLUDING END USERS SUCH AS ASSET MANAGERS AND THEIR CLIENTS. PROTECTING DATA & PRIVACY: PERSONAL FINANCIAL INFORMATION IS INVALUABLE AND THE FINANCIAL INDUSTRY IS COMMITTED TO ENSURING THE SAFETY OF THE CLIENTS WE SERVE AT EVERY TURN. SIFMA BELIEVES A FEDERAL PRIVACY AND DATA BREACH STANDARD IS NECESSARY TO BEST PROTECT THE PERSONAL FINANCIAL DATA OF ALL AMERICANS. MANY OF OUR MEMBERS FUNCTION REGIONALLY, NATIONALLY, AND GLOBALLY, AND THE CURRENT PATCHWORK OF CONFLICTING STATE AND FEDERAL LAWS AND REGULATIONS FURTHER ADDS TO THE CONFUSION AND INEFFICIENCY. ADOPTING A FEDERAL PREEMPTIVE STANDARD FOR PRIVACY AND DATA BREACH THAT TAKES INTO CONSIDERATION EXISTING POLICIES UNDER THE GRAMM-LEACH-BLILEY ACT WOULD GREATLY IMPROVE CUSTOMER PROTECTION BY MINIMIZING CONFUSION AND INEQUALITY. INVESTORS ARE INCREASINGLY LOOKING FOR TRANSPARENCY AS THEY DETERMINE HOW THEIR DATA IS BEING SHARED, USED AND PROTECTED. TO THAT END, SIFMA HAS PUBLISHED A SET OF INDUSTRY-WIDE PRINCIPLES, FOCUSING ON ACCESS; SECURITY AND RESPONSIBILITY; TRANSPARENCY AND PERMISSION; AND SCOPE OF ACCESS AND USE, FOR PROTECTING, SHARING AND AGGREGATING CUSTOMER FINANCIAL INFORMATION. SIFMA IS ALSO A FOUNDING MEMBER AND SERVE ON THE BOARD OF THE FINANCIAL DATA EXCHANGE (FDX), A NON-PROFIT STANDARDS BODY TASKED WITH DEVELOPING TECHNICAL SOLUTIONS FOR PERMISSIONED DATA TRANSFER BETWEEN FINANCIAL INSTITUTIONS AND TECHNOLOGY COMPANIES. IMPLEMENTING THE CONSOLIDATED AUDIT TRAIL: THE SEC ESTABLISHED THE CONSOLIDATED AUDIT TRAIL (THE CAT) TO ENABLE REGULATORS TO TRACK ALL ORDER AND TRADING ACTIVITY THROUGHOUT THE U.S. MARKETS FOR LISTED EQUITIES AND OPTIONS. WHILE OPERATED BY 25 SELF-REGULATORY ORGANIZATIONS (SROS) INCLUDING EQUITY AND OPTIONS EXCHANGES, UNDER THE SUPERVISION OF THE SEC, THE SECURITIES INDUSTRY HAS UNDERTAKEN EFFORTS TO BUILD AND STAND UP SYSTEMS NECESSARY TO COMPLY WITH THE CAT, WORKING DILIGENTLY THROUGH THE CORONAVIRUS PANDEMIC AND THE OPERATIONAL CHANGES, PRIORITIES AND DEMANDS IT BROUGHT. THE TRANSACTION DATABASE BECAME FULLY IMPLEMENTED IN DECEMBER 2021. THE SROS AND INDUSTRY ARE NOW WORKING ON THE DESIGN AND DEVELOPMENT OF THE CUSTOMER DATA BASE OR CAIS WHICH IS PROJECTED TO COME ONLINE IN MID-2022. THE DATA WITHIN CAT HAS BECOME A KEY REGULATORY TOOL AS EVIDENCED BY THE OCTOBER 2021 SEC STAFF REPORT ON JANUARY 2021 MARKET VOLATILITY WHICH USED CAT DATA TO RECREATE AND ANALYZE THE TRADING ACTIVITY. SEVERAL CRITICAL ISSUES REMAIN, MOST IMPORTANTLY DATA SECURITY AND FUNDING. SIFMA HAS CONTINUALLY VOICED CONCERNS ABOUT THE TYPE AND AMOUNT OF PERSONALLY IDENTIFIABLE INFORMATION (PII) DATA TO BE REPORTED TO AND MAINTAINED IN THE CAIS AND HAS REPEATEDLY OFFERED VIABLE ALTERNATIVES THAT WOULD SERVE THE SAME PURPOSE WITHOUT THE ATTENDANT DATA AND PRIVACY RISK TO INVESTORS. WE CONTINUE TO ENGAGE WITH THE SEC ON ITS AUGUST 2020 DATA SECURITY PROPOSAL WHICH WOULD, AMONG OTHER THINGS, PROHIBIT THE BULK DOWNLOADING OF CAT DATA AND WOULD STRICTLY AND CLEARLY PROHIBIT THE USE OF CAT DATA FOR ANY COMMERCIAL PURPOSE. WE CONTINUE TO ADVOCATE FOR A COLLABORATIVE, EQUITABLE AND TRANSPARENT FUNDING MODEL FOR THE CAT AND RECOMMENDED THAT THE COMMISSION DISAPPROVE THE PROPOSED MODEL SUBMITTED BY THE SROS. 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. 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. PROTECTING SENIOR INVESTORS: BY 2030, SENIORS AGED 65 AND OVER WILL MAKE UP 18% OF THE NATION'S POPULATION. IN THE UNITED STATES, SENIORS LOSE AN ESTIMATED $2.9 BILLION EVERY YEAR IN CASES OF FINANCIAL EXPLOITATION REPORTED BY MEDIA OUTLETS, WHILE ONLY AN ESTIMATED 1 IN 44 CASES IS EVEN REPORTED TO AUTHORITIES. IT IS VITAL THAT WE ARE ABLE TO PROTECT OUR SENIOR INVESTORS FROM FINANCIAL EXPLOITATION AND THE DANGERS OF COGNITIVE DECLINE. SIFMA IS COMMITTED TO WORKING ACROSS THE FINANCIAL INDUSTRY TO PROTECT SENIOR INVESTORS AND CONTINUES TO SEEK NEW WAYS TO FIGHT AGAINST FINANCIAL EXPLOITATION OF OLDER AMERICANS. IN ADDITION TO OUR SENIOR INVESTOR PROTECTION TOOLKIT, WE WORK IN PARTNERSHIP WITH AARP TO DISTRIBUTE THE BANKSAFE TRAINING PROGRAM AND WITH ORGANIZATIONS INCLUDING THE WOMEN'S INSTITUTE FOR A SECURE RETIREMENT (WISER), THE NATIONAL ADULT PROTECTIVE SERVICES ASSOCIATION (NAPSA), FINRA AND MORE. PRESERVING 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. INDEPENDENT BROKER-DEALERS (IBDS) AND THE NEARLY 160,000 INDIVIDUALS THAT AFFILIATE WITH THEM AS INDEPENDENT FINANCIAL ADVISORS (IFAS) SERVE MILLIONS OF CLIENTS ACROSS THE U.S. BY PROVIDING INVESTMENT ADVICE AND EDUCATION. IFAS PROVIDE CRUCIAL ADVICE ON RETIREMENT PLANNING, EDUCATIONAL FUNDING, AND OTHER LIFE EVENTS RETAIL INVESTORS IN ADDITION TO OFFERING OTHER SERVICES AND PRODUCTS, SUCH AS INSURANCE AND TAX PLANNING, THAT ADDRESS THEIR CLIENTS' FINANCIAL WELL-BEING HOLISTICALLY. INDEPENDENT CONTRACTOR STATUS ALLOWS INDEPENDENT FINANCIAL ADVISORS TO OWN AND OPERATE THEIR OWN SMALL BUSINESS. INDEPENDENT FINANCIAL ADVISORS ALSO BENEFIT FROM A DECENTRALIZED BUSINESS STRUCTURE, WHICH EXPANDS THE ACCESSIBILITY OF FINANCIAL ADVICE AND PLANNING IN PARTS OF THE COUNTRY THAT WOULD OTHERWISE NOT BE SERVED. NOTABLY, INDEPENDENT FINANCIAL ADVISORS WORK IN A HIGHLY REGULATED INDUSTRY AND ARE REQUIRED BY SECURITIES LAWS TO ASSOCIATE WITH A BROKER-DEALER TO PROTECT INVESTORS. WE ENCOURAGE LAWMAKERS TO EXEMPT INDEPENDENT BROKER DEALERS AND INDEPENDENT FINANCIAL ADVISORS FROM ANY LEGISLATION, SUCH AS THE PROTECTING RIGHTS TO ORGANIZE ACT (PRO ACT), THAT WOULD PREVENT FINANCIAL SERVICES PROFESSIONALS FROM FREELY CHOOSING TO BE INDEPENDENT CONTRACTORS.
FORM 990, PART III, LINE 4B	PRUDENTIAL REGULATION OF 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, PARTICULARLY AS REGULATORS CONSIDER THE IMPLEMENTATION OF ELEMENTS OF THE BASEL III CAPITAL PROPOSAL IN 2022, INCLUDING THE FUNDAMENTAL REVIEW OF THE TRADING BOOK (FRTB) AND CREDIT VALUATION ADJUSTMENT (CVA). IT IS VITAL THAT THOSE RULES SHOULD BE IMPLEMENTED IN A MANNER THAT DOES NOT OVERLY PENALIZE BANKS' CAPITAL MARKETS ACTIVITIES, WHICH IN TURN COULD REDUCE LIQUIDITY IN VITAL CORPORATE AND OTHER FUNDING MARKETS, THEREBY HURTING GROWTH IN 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. 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. IT IS THUS CRUCIAL TO ALIGN AND ALLOW FOR MUTUAL RECOGNITION, TO THE EXTENT POSSIBLE, THE CAPITAL AND LIQUIDITY STANDARDS SET OUT BY THE U.S. BANKING REGULATORS AND THE MARKET REGULATORS. TAX POLICY TO SUPPORT 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. SIFMA BELIEVES TAXES IMPACT SAVINGS AND INVESTMENTS FOR BOTH INDIVIDUALS AND BUSINESSES, BUT REMAIN NECESSARY FOR GOVERNMENT PROGRAMS AND SUPPORT FOR DOMESTIC ECONOMIC GROWTH. WE REMAIN FOCUSED ON INTERNATIONAL TAX, CAPITAL GAINS AND DIVIDENDS AS WELL AS PROTECTING INVESTORS AND SAVERS FROM TAXES THAT COULD HURT THEIR FUTURE SAVINGS. FOSTERING DIVERSITY, EQUITY & INCLUSION: SIFMA ADVOCATES FOR A DIVERSE AND INCLUSIVE FINANCIAL INDUSTRY. TOGETHER WITH OUR MEMBERS, WE 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.
FORM 990, PART III, LINE 4C	STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS CONFERENCES AND EVENTS: WWW.SIFMA.ORG/EVENTS SIFMA CONFERENCES, EVENTS AND WEBINARS FOSTER MEANINGFUL CONVERSATIONS ABOUT THE CAPITAL MARKETS AND OFFER VALUABLE PROFESSIONAL DEVELOPMENT OPPORTUNITIES. SIFMA ANNUAL MEETING: BROKER-DEALERS, INVESTMENT BANKS AND ASSET MANAGERS ACCESS THE CAPITAL MARKETS TO DELIVER A BROAD RANGE OF FINANCIAL SERVICES TO CLIENTS INCLUDING CORPORATIONS, GOVERNMENTS AND INDIVIDUALS. AS THE VOICE FOR THE NATION'S SECURITIES INDUSTRY, SIFMA BRINGS TOGETHER OUR MEMBERS TO ADVOCATE FOR EFFECTIVE AND EFFICIENT CAPITAL MARKETS. TOGETHER, WE ARE INVESTED IN AMERICA. OUR ANNUAL MEETING GATHERS THE MOST INFLUENTIAL VOICES SHAPING THE CAPITAL MARKETS FROM A CROSS-SECTION OF PUBLIC POLICY AND FINANCE. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR: SIFMA'S C&L ANNUAL SEMINAR IS THE PREEMINENT MEETING PLACE FOR COMPLIANCE AND LEGAL PROFESSIONALS IN FINANCIAL SERVICES TO GAIN AN UNDERSTANDING OF WHAT'S NEXT FOR THE MARKETS AND THE CLIENTS WE SERVE. OVER THREE DAYS OF SUBSTANTIVE PROGRAMMING, NETWORKING AND ACTIVITIES, WE GAIN INSIGHTS YOU WON'T FIND ANYWHERE ELSE. OPERATIONS CONFERENCE & EXHIBITION: FOR FIVE DECADES, SIFMA'S OPERATIONS CONFERENCE & EXHIBITION HAS GATHERED OPERATIONS, TECHNOLOGY, AND REGULATORY LEADERS TO DRIVE FORWARD INDUSTRY-WIDE INITIATIVES THAT HELPED SHAPE THE EVOLUTION OF THE U.S. CAPITAL MARKETS. 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 71 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 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 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 1,995,277.

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

Cat. No. 51056K

Schedule O (Form 990) 2021

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 (CONT. ON SCH. O) 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	48
4	Number of independent voting members of the governing body (Part VI, line 1b) .....	4	47
5	Total number of individuals employed in calendar year 2021 (Part V, line 2a) ......	5	139
6	Total number of volunteers (estimate if necessary) .............	6	17,287
7a	Total unrelated business revenue from Part VIII, column (C), line 12 ........	7a	260,332
b	Net unrelated business taxable income from Form 990-T, Part I, line 11 .........	7b	127,922

		Prior Year	Current Year
8	Contributions and grants (Part VIII, line 1h) .........	0	0
9	Program service revenue (Part VIII, line 2g) .........	46,783,222	53,640,701
10	Investment income (Part VIII, column (A), lines 3, 4, and 7d ) ....	215,742	378,686
11	Other revenue (Part VIII, column (A), lines 5, 6d, 8c, 9c, 10c, and 11e)	658,217	749,233
12	Total revenue—add lines 8 through 11 (must equal Part VIII, column (A), line 12)	47,657,181	54,768,620
13	Grants and similar amounts paid (Part IX, column (A), lines 1–3 )...	193,519	209,229
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)	34,688,229	35,342,397
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)....	14,408,725	17,803,327
18	Total expenses. Add lines 13–17 (must equal Part IX, column (A), line 25)	49,290,473	53,354,953
19	Revenue less expenses. Subtract line 18 from line 12.......	-1,633,292	1,413,667
		Beginning of Current Year	End of Year
20	Total assets (Part X, line 16).............	42,827,387	45,548,628
21	Total liabilities (Part X, line 26).............	24,933,317	25,752,434
22	Net assets or fund balances. Subtract line 21 from line 20.....	17,894,070	19,796,194

Sign Here

	Signature of officer	Date

	Type or print name and title


4a	(Code: ) (Expenses $ including grants of $ ) (Revenue $ )
	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)...........	9,866,016	0	778,787

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	40,472,762	40,472,762
b	CONFERENCES	541900	13,061,490	13,061,490
c	PUBLICATION SALES	900099	106,449	100,149	6,300
d
e
f	All other program service revenue.
g	Total. Add lines 2a–2f .....		53,640,701

3 Investment income (including dividends, interest, and othersimilar amounts) ......			378,686			378,686
4 Income from investment of tax-exempt bond proceeds
5 Royalties...........			254,788		254,032	756
		(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	423,676			423,676
b	MISCELLANEOUS REVENUE		900099	70,769			70,769
c
d	All other revenue ....
e	Total. Add lines 11a–11d ......			494,445
12	Total revenue. See instructions.....			54,768,620	53,634,401	260,332	873,887

1	Grants and other assistance to domestic organizations and domestic governments. See Part IV, line 21 ....	209,229
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 ...........	7,845,685
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........	21,899,335
8	Pension plan accruals and contributions (include section 401(k) and 403(b) employer contributions) ....	1,794,538
9	Other employee benefits .......	2,413,986
10	Payroll taxes ...........	1,388,853
11	Fees for services (non-employees):
a	Management ......	46,608
b	Legal .........	1,464,108
c	Accounting ...........	142,373
d	Lobbying ...........	567,784
e	Professional fundraising services. See Part IV, line 17
f	Investment management fees ......	12,458
g	Other (If line 11g amount exceeds 10% of line 25, column (A) amount, list line 11g expenses on Schedule O)	1,433,405
12	Advertising and promotion ....
13	Office expenses .......	557,418
14	Information technology ......	725,369
15	Royalties ..
16	Occupancy ...........	3,491,582
17	Travel ............	704,584
18	Payments of travel or entertainment expenses for any federal, state, or local public officials .
19	Conferences, conventions, and meetings ....	5,717,116
20	Interest ...........
21	Payments to affiliates .......
22	Depreciation, depletion, and amortization ..	1,425,155
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	645,911
b	UBTI/EXCISE TAX EXPENSE	344,185
c	BANK CHARGES & CC FEES	229,854
d	DUES & REGISTRATION	174,528
e	All other expenses	120,889
25	Total functional expenses. Add lines 1 through 24e	53,354,953
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 ........			2,859,342	1	1,647,486
2	Savings and temporary cash investments .........			16,880,911	2	18,370,622
3	Pledges and grants receivable, net ......				3
4	Accounts receivable, net .............			65,417	4	75,210
5	Loans and other receivables from 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 ......			2,500,195	9	2,833,152
10a	Land, buildings, and equipment: cost or other basis. Complete Part VI of Schedule D	10a	9,785,808
b	Less: accumulated depreciation	10b	2,066,852	4,019,514	10c	7,718,956
11	Investments—publicly traded securities .			14,203,814	11	12,864,205
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 ...........			2,298,194	15	2,038,997
16	Total assets. Add lines 1 through 15 (must equal line 33)...			42,827,387	16	45,548,628

17	Accounts payable and accrued expenses .....	10,143,524	17	10,661,377
18	Grants payable ...		18
19	Deferred revenue .........	3,160,888	19	2,845,067
20	Tax-exempt bond liabilities .........		20
21	Escrow or custodial account liability. Complete Part IV of Schedule D	276,532	21	126,543
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	11,352,373	25	12,119,447
26	Total liabilities. Add lines 17 through 25..	24,933,317	26	25,752,434

	Organizations that follow FASB ASC 958, check here and complete lines 27, 28, 32, and 33.
27	Net assets without donor restrictions ..........	17,894,070	27	19,796,194
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 ...........	17,894,070	32	19,796,194
33	Total liabilities and net assets/fund balances ........	42,827,387	33	45,548,628