TIN:
SCHEDULE O
(Form 990)
Department of the Treasury
Internal Revenue Service
(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.
Attach to Form 990 or 990-EZ.
Go to www.irs.gov/Form990 for the latest information.
OMB No. 1545-0047
2021
Open to Public
Inspection
Inspection
Name of the organization
SECURITIES INDUSTRY AND FINANCIAL
MARKETS ASSOCIATION
MARKETS ASSOCIATION
Employer identification number
32-0178959
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 THE FINANCIAL SERVICES SECTOR IS IDENTIFIED AS CRITICAL INFRASTRUCTURE 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 BOLDER 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 CYCLE: THROUGH A MASSIVE UNDERTAKING, THE FINANCIAL INDUSTRY WILL TRANSITION TO A T+1 SETTLEMENT CYCLE IN THE UNITED STATES ON TUESDAY, MAY 28, 2024, AND IN CANADA ON MONDAY, MAY 27, 2024. ENHANCING OUR SECURITIES SETTLEMENT PROCESS IS CRITICAL TO THE CONTINUED RESILIENCY OF OUR MARKETS AND MARKET OPERATIONS. A T+1 SETTLEMENT CYCLE WILL REDUCE SETTLEMENT RISK, 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 AREAS - ALLOCATIONS, AFFIRMATION AND DISAFFIRMATION PROCESSES, CLEARINGHOUSE PROCESS TIMELINES, AND SECURITIES LENDING - WILL 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. THE SEC RULEMAKING AGENDA: WWW.SIFMA.ORG/EXPLORE-ISSUES/SEC-RULEMAKING-AGENDA IT IS CRITICAL THAT REGULATORS TAILOR POLICIES TO ADDRESS LEGITIMATE MARKET FAILURES WITHOUT UNNECESSARILY HARMING OR DISRUPTING MARKETS, ESPECIALLY WHEN THE GLOBAL ECONOMY FACES SERIOUS HEADWINDS. HOWEVER, THE HIGH VOLUME AND SPEED OF REGULATORY CHANGE PROPOSED BY THE U.S. SECURITIES AND EXCHANGE COMMISSION COULD RESULT IN NEGATIVE CONSEQUENCES FOR THE REAL ECONOMY. THE DATA DEMONSTRATES THAT THESE CONCERNS ARE WELL-FOUNDED. IN ADDITION TO CONCERNS REGARDING THE UNPRECEDENTED VOLUME, COMMENTERS, INCLUDING SIFMA, HAVE EXPRESSED CONCERN THAT TRUNCATED TIMELINES FOR MULTIPLE OVERLAPPING RULE PROPOSALS LIMIT STAKEHOLDER'S ABILITY TO ANALYZE THE COLLECTIVE IMPACT OF THE PROPOSALS. FAILURE TO DO SO CAN RESULT IN CONFLICTING AND POORLY DRAFTED RULES WITH THE POTENTIAL FOR NEGATIVE IMPACTS ON CAPITAL MARKETS AND, IMPORTANTLY, INVESTORS AND ISSUERS. THERE IS JUSTIFICATION FOR CERTAIN RULES, SUCH AS THE TRANSITION OF THE SECURITIES SETTLEMENT CYCLE FROM TWO DAYS TO ONE, WHICH SIFMA AND THE INDUSTRY STRONGLY SUPPORT, OR THOSE MANDATED BY THE DODD-FRANK ACT. HOWEVER, THE SEC HAS NOT SUFFICIENTLY PRIORITIZED ITS AGENDA, AND IN SEVERAL CASES IS ACTING WITHOUT CLEAR EVIDENCE OF MARKET FAILURE OR DIRECTION FROM CONGRESS. THE AGENDA ALSO LACKS PRIORITIZATION AND SUFFICIENT COST-BENEFIT ANALYSIS, PARTICULARLY THE CUMULATIVE IMPACT OF THIS ONSLAUGHT OF RULEMAKING. LACK OF PRIORITIZATION AND PURSUIT OF NOVEL PROPOSALS HAS CROWDED OTHER IMPORTANT MANDATES, SUCH AS THE PENDING DATA SECURITY RULE FOR THE CONSOLIDATED AUDIT TRAIL (CAT), THE LARGEST SECURITIES TRANSACTION DATABASE EVER CREATED WHICH COLLECTS TRADE DATA AND CUSTOMER PERSONALLY IDENTIFIABLE INFORMATION, OR PII, ON EVERY STOCK AND OPTION TRANSACTION. THAT PROPOSAL HAS BEEN PENDING FOR OVER THREE YEARS. PERHAPS THE MOST CONTROVERSIAL AND LEAST CONSIDERED ASPECT OF THE SEC'S AGENDA ARE THE PROPOSED REFORMS TO EQUITY MARKET STRUCTURE. THESE PROPOSALS WOULD DRAMATICALLY OVERHAUL THE STRUCTURE GOVERNING U.S. EQUITY MARKETS AND POTENTIALLY UNDERMINE THE RECENT EXPANSION OF MARKET ACCESS THAT INVESTORS ENJOY TODAY. STAKEHOLDERS FROM ALL CORNERS OF THE MARKETS HAVE VOICED OPPOSITION TO THE PROPOSALS WITH ONE EXCEPTION: THE PROPOSAL TO UPDATE RULE 605, WHICH WOULD UPDATE THE DATA THAT MEASURES MARKET QUALITY FOR EVERYDAY INDIVIDUAL INVESTORS AND IS A NATURAL STARTING POINT TO ASSESS THE NEED FOR FURTHER REFORMS. THE COMMISSION HAS A DUTY TO ENSURE FAIR, ORDERLY AND EFFICIENT MARKETS. RUSHING TO DO TOO MUCH TOO QUICKLY COULD RESULT IN POOR POLICY OUTCOMES AND OVERWHELM MARKET INFRASTRUCTURE, PUTTING THE VERY MARKETS THEY ARE TRYING TO PROTECT AT GRAVE RISK. PRUDENTIAL REGULATION IMPACT ON CAPITAL MARKETS: WWW.SIFMA.ORG/EXPLORE-ISSUES/PRUDENTIAL-REGULATION PRUDENTIAL REGULATION REQUIRES BANKS TO OPERATE IN A SAFE AND SOUND MANNER, 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 THE BASEL III ENDGAME PACKAGE OF REFORMS, 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 CAPITAL MARKETS ACTIVITIES BY BANKS' AFFILIATED BROKER-DEALERS, 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 CAN RESULT IN INCREASED COSTS 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 EFFICIENCIES BY INCREASING COSTS TO END USERS. IT IS THUS CRUCIAL TO ALIGN, TO THE EXTENT POSSIBLE, THE CAPITAL AND LIQUIDITY STANDARDS SET OUT BY THE U.S. BANKING REGULATORS AND THE MARKET REGULATORS. 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. WORKING WITH OUR MEMBERS WHO SERVE RETAIL INVESTORS, SIFMA SEEKS TO RAISE AWARENESS OF HOW FINANCIAL ADVICE AND FINANCIAL LITERACY PROGRAMS CAN POSITIVELY IMPACT THE FINANCIAL HEALTH OF AMERICANS WORKING TO REACH THEIR FINANCIAL GOALS, INCLUDING PURCHASING A HOME, SENDING CHILDREN TO COLLEGE AND SAVING FOR RETIREMENT. CHANGING DEMOGRAPHICS 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 $8.7 TRILLION IN ASSETS, GROWING AT A 6.8% 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 HALF 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 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. IN OCTOBER 2023, THE U.S. DEPARTMENT OF LABOR RELEASED A PROPOSED "RETIREMENT SECURITY RULE" MEANT TO EXPAND THE EXISTING FIDUCIARY STANDARD THAT COMMONLY COVERS ADVICE OVER PURCHASING SECURITIES LIKE MUTUAL FUNDS, TO INCLUDE NEW TYPES OF NON-SECURITIES LIKE FIXED INDEX ANNUITIES, ADVICE TO EMPLOYERS AND PLAN FIDUCIARIES, AND ONETIME ADVICE FOR TRANSACTIONS LIKE 401(K) ROLLOVERS. SINCE THE DEPARTMENT OF LABOR (DOL) FIRST PROPOSED A CHANGE TO THE DEFINITION OF FIDUCIARY, THE LANDSCAPE HAS CHANGED GREATLY, MOST NOTABLY WITH THE IMPLEMENTATION OF REGULATION BEST INTEREST (REG BI) IN 2020. REG BI IMPLEMENTED A BEST INTEREST STANDARD THAT DID NOT EXIST AT THE TIME OF THE 2015 DOL RE-PROPOSAL AND FOUNDATIONALLY IMPROVED THE PROTECTIONS IN PLACE FOR RETIREMENT SAVERS. SIFMA LONG SUPPORTED A BEST INTEREST STANDARD OF CARE FOR BROKERS. THAT STANDARD IS NOW IN PLACE, IT IS ROBUST AND EXPANSIVE WITH SIGNIFICANT DUTIES AND OBLIGATIONS IMPOSED ON BROKER-DEALERS THAT UNQUESTIONABLY ENHANCES INVESTOR PROTECTION. SIFMA IS CONCERNED THAT THE DEPARTMENT'S NEWEST PROPOSAL MAY GO TOO FAR, INCONSISTENT WITH EXISTING FEDERAL REGULATIONS SUCH AS REG BI AND AS A RESULT COULD LIMIT ACCESS TO ADVICE AND EDUCATION WHILE ALSO LIMITING INVESTOR CHOICE IN ADVISORS. |
| FORM 990, PART III, LINE 4B | ON THE OTHER HAND, THE SECURE ACT 2.0 IS AN IMPORTANT STEP TOWARD ENHANCING THE PRIVATE RETIREMENT SYSTEM AND INCREASING RETIREMENT SAVINGS. SIGNED INTO LAW IN DECEMBER 2022, THE ACT INCLUDES IMPORTANT PROVISIONS SUCH AS HIGHER CATCH-UP CONTRIBUTIONS FOR WORKPLACE PLANS, AN INCREASE IN THE REQUIRED MINIMUM DISTRIBUTION (RMD) AGE, AND AN AVENUE FOR THE CREATION OF EMERGENCY SAVINGS ACCOUNTS. SECURE 2.0 REPRESENTS A MAJOR VICTORY FOR EMPLOYERS, INDIVIDUALS, AND THE RETIREMENT SYSTEM AND SIFMA IS PROUD TO HAVE SUPPORTED ITS PASSAGE. 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. INVESTORS INCREASINGLY CHOOSE ADVICE: DEMAND FOR FINANCIAL ADVICE IS GROWING AND INVESTORS ARE INCREASINGLY SATISFIED WITH ADVICE OFFERINGS, ACCORDING TO THE REPORT. THE EVOLVING FUTURE OF WEALTH MANAGEMENT. DESPITE A SEEMINGLY UNLIMITED ARRAY OF INFORMATION AND TOOLS DESIGNED TO EMPOWER INVESTORS TO TAKE AN ACTIVE ROLE IN MANAGING THEIR OWN INVESTMENTS, THE DEMAND FOR HANDS-ON ADVISORS CONTINUES TO INCREASE. 63% OF INVESTORS INDICATE A WILLINGNESS TO PAY FOR ADVICE, UP FROM 38% IN 2009. IN THIS JOINT RESEARCH PROJECT FROM CERULLI ASSOCIATES AND SIFMA, WE ANALYZE THE FACTORS THAT MATTER MOST TO INVESTORS AS THEY PLACE GREATER RELIANCE ON FINANCIAL ADVISORS. WE ALSO DISCUSS WHY, TO ENSURE LONG-TERM CLIENT GROWTH, PROVIDERS WILL NEED TO OFFER SCALABLE OMNI-CHANNEL HYBRID ADVICE SOLUTIONS TO ENGAGE CLIENTS BEFORE THEY HAVE MET TRADITIONALLY TARGETED WEALTH LEVELS. AML & FINANCIAL CRIME: AN EFFECTIVE ANTI-MONEY LAUNDERING PROGRAM IS A CRITICAL TOOL TO FIGHT FINANCIAL CRIME AND PROTECT THE INTEGRITY OF THE CAPITAL MARKETS AND GLOBAL FINANCIAL SYSTEM. ANTI-MONEY LAUNDERING AND FINANCIAL CRIME PROFESSIONALS AT BROKER-DEALERS HAVE A UNIQUE ROLE IN COMBATTING ILLICIT FINANCE. NEVER HAS THERE BEEN A MORE DYNAMIC AND HOPEFUL TIME FOR THEIR EFFORTS TO PROTECT AND ENSURE THE PREEMINENCE OF THE U.S. CAPITAL MARKETS. THESE PROFESSIONALS CONDUCT SUBSTANTIAL SURVEILLANCE OF FUND MOVEMENTS IN ADDITION TO TRANSACTION MONITORING; THEY USE KNOW YOUR CUSTOMER (KYC) PROCESSES TO LOOK CRITICALLY AT SOURCES OF FUNDS FOR THEIR CUSTOMERS TO IDENTIFY SUSPICIOUS ACCOUNT OPENINGS OR ACCOUNT FUNDINGS; AND THEY REGULARLY ANALYZE ACTIVITY TO IDENTIFY ILLICIT SCHEMES THAT MAY BE NEW TO THEIR FIRMS. THEY FILE A SIGNIFICANT NUMBER OF SUSPICIOUS ACTIVITY REPORTS (SARS), AIDING LAW ENFORCEMENT'S INVESTIGATIVE EFFORTS. THE ANTI-MONEY LAUNDERING ACT OF 2020, WHICH BECAME LAW ON JANUARY 1, 2021, IS THE MOST SIGNIFICANT PIECE OF AML RELATED LEGISLATION SINCE THE USA PATRIOT ACT OF 2001. SIFMA IS COMMITTED TO HELPING OUR MEMBERS INCORPORATE IT INTO THEIR RISK-BASED PROGRAMS, AND WE CONTINUE TO ENGAGE WITH THE TREASURY AND OTHER POLICY MAKERS ON NEW AND MODIFIED REQUIREMENTS FOCUSED ON MITIGATING FINANCIAL CRIME RISKS ACROSS THE SECURITIES INDUSTRY. BROKER-DEALERS AND OTHER FINANCIAL INSTITUTIONS HOPE THAT REGULATORS TASKED WITH IMPLEMENTING THE ACT REMAIN FAITHFUL IN THEIR RULEMAKINGS TO THE AML ACT'S PURPOSE TO MODERNIZE EXISTING, CUMBERSOME REGULATIONS THAT DRAIN CRITICAL RESOURCES AWAY FROM THE MOST THREATENING ILLICIT FINANCE RISKS. IT IS CRITICAL THAT WE ALSO LOOK TO NEW BUSINESS LINES AND PRODUCTS, INCLUDING THE MARIJUANA INDUSTRY AND DIGITAL ASSETS, WHICH MAY PRESENT THE SAME OR ADDITIONAL ILLICIT FINANCE RISKS. SIFMA HAS BEEN AT THE FOREFRONT IN ASSISTING OUR MEMBERS AS THEY NAVIGATE THIS EVER-CHANGING AND MORE COMPLEX LANDSCAPE. THE FINANCIAL INDUSTRY DEDICATES TREMENDOUS TIME, DILIGENCE AND RESOURCES TO PROTECTING OUR FINANCIAL SYSTEM. WE REMAIN COMMITTED TO WORKING TOGETHER, SHARING INFORMATION AND BEST PRACTICES, AND LEARNING FROM EACH OTHER ALL WITH THE GOAL OF PROTECTING OUR MARKETS FROM ILLICIT FINANCIAL ACTIVITY AND STAYING A STEP OF THOSE LOOKING TO EXPLOIT THEM. FOSTERING DIVERSITY & INCLUSION: DIVERSITY AND INCLUSION ARE ISSUES 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. THROUGH A SIX-PILLAR APPROACH, SIFMA'S DIVERSITY & INCLUSION ADVISORY COUNCIL ASSISTS MEMBER FIRMS IN DEVELOPING THEIR DIVERSITY INITIATIVES TO INCREASE INCLUSION IN THE WORKPLACE AND IN THEIR EFFORTS TO MARKET TO DIVERSE CUSTOMERS. FOR MORE THAN 20 YEARS, THE COUNCIL HAS CONDUCTED A BENCHMARK SURVEY AND ENCOURAGES MORE OF OUR MEMBER FIRMS TO PARTICIPATE. 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. OUR MOST RECENT 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 INDUSTRY MUST NOW FOCUS ON PROMOTING FEMALE EMPLOYEES TO EXECUTIVE RANKS AND RETAINING ETHNICALLY DIVERSE TALENT. THROUGH OUR SIX-PILLAR APPROACH, SIFMA IS RAISING AWARENESS OF THIS NEED. WE ARE ALSO WORKING SPECIFICALLY WITH ASSET MANAGERS TO ADVANCE THE WORK OF MINORITY-, WOMEN-, AND VETERAN-OWNED BUSINESSES. 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. SIFMA HAS ALSO PARTNERED WITH THE MILKEN INSTITUTE'S HBCU STRATEGIC INITIATIVE AND FELLOWSHIP PROGRAM, WHICH AIMS TO EMPOWER STUDENTS FROM HBCUS BY EQUIPPING THEM WITH THE SKILLS AND CONNECTIONS NECESSARY FOR SUCCESSFUL CAREERS IN FINANCE AND THE FUNDAMENTALS OF WALL STREET. FOLLOWING A SUCCESSFUL LAUNCH IN 2023, THE 2024 COHORT WILL INCLUDE 20 NEW FELLOWS FROM A VARIETY OF HBCUS. |
| 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: HTTPS://EVENTS.SIFMA.ORG/ SIFMA CONFERENCES, EVENTS AND WEBINARS FOSTER MEANINGFUL CONVERSATIONS ABOUT THE CAPITAL MARKETS AND OFFER VALUABLE PROFESSIONAL DEVELOPMENT OPPORTUNITIES. SIFMA ANNUAL MEETING: CAPITAL MARKETS FINANCE THE REAL ECONOMY, ALLOCATE RISK, AND SUPPORT ECONOMIC GROWTH AND FINANCIAL STABILITY. AS THE VOICE FOR THE NATION'S SECURITIES INDUSTRY, WHICH DELIVERS A BROAD RANGE OF FINANCIAL SERVICES TO CLIENTS INCLUDING CORPORATIONS, GOVERNMENTS AND INDIVIDUALS, SIFMA BRINGS TOGETHER HUNDREDS OF INVESTMENT BANKS, WEALTH MANAGERS, BROKER-DEALERS AND ASSET MANAGERS TO ADVOCATE FOR THEIR EFFECTIVENESS AND RESILIENCY CAPITAL MARKETS. TOGETHER, WE ARE INVESTED IN AMERICA. SIFMA'S 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. 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 72 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 -223,618. |
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: |