SIFMA C&L Society Update: January 2025 Edition

Greetings and welcome to the SIFMA C&L Society’s January Update! Was this newsletter forwarded to you? Sign up here.

The policy and regulatory landscapes are changing...

The past several years was marked by a prolific rulemaking agenda, wrote SIFMA president and CEO Kenneth E. Bentsen, Jr. in a recent post. In many cases, in part due to strong advocacy efforts, many major rules were modified or did not proceed. Today, we have a new administration, new Congress, and new heads of the regulatory agencies. What will it all mean?

At the 2025 SIFMA C& Annual Seminar, we’ll talk with industry experts and regulators to illuminate the road ahead. Our program features seasoned voices including:

• Roberto Braceras , General Counsel, 富达 ?
• Robert Cook , President and CEO, FINRA ?
• Stacey Friedman, Executive Vice President and General Counsel, 摩根大通 ?
• Eric F. Grossman , Executive Vice President and Chief Legal Officer, 摩根士丹利 ?
• Kristin Johnson , Commissioner, U.S. Commodity Futures Trading Commission ?
• Stefan Simon , Chief Executive Officer Americas and Chief Legal Officer, 德意志银行 ?
• William St. Louis , Executive Vice President and Head of Enforcement, FINRA ?

With many more are still to be announced. From March 23–26, Austin is the place to be! Browse our program and register today.?

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We know that attending an event like the Annual Seminar is an investment. Here’s a letter to help you define the value proposition for you and your organization. First-time registrant? Contact us at [email protected] to find out if you are eligible for?discounted rates.

FEATURED EVENTS

Gain insight into critical issues for compliance and legal professionals in financial services with these industry-leading events:?

C&L Society Forum: FINRA's 2025 Regulatory Operations Programs?

February 4, 2025 | New York, NY?

Join the Waitlist?

Women's Leadership Forum DC?

February 5, 2025 | Washington, DC?

Join the Waitlist?

C&L Annual Seminar?

March 23-26, 2025 | Austin, TX?

Register Today?

AML 2025?

May 13-14, 2025 | Washington, DC?

Register Today?

View more events at?www.sifma.org/events?

FEATURED COMMENTS & FILINGS?

Comment Letters:?

• Request for Information on the MSRB’s Rate Card Process (SIFMA Letter)?

• Extension Request Re: Standards for Covered Clearing Agencies for US Treasury Securities and Application of the Broker-Dealer Customer Protection Rule with Respect to US Treasury Securities (Joint Trades Letter)?

• IOSCO Consultation Report on Digital Engagement Practices (SIFMA and SIFMA AMG Letter)?

• Proposed Amendments to Rule 801 (SIFMA and SIFMA AMG Letter)?

• Extension: Municipal Securities Disclosure (Exchange Act Rule 15c2–12) (SIFMA Letter)?

• Missouri Rule Proposals (SIFMA Letter)?

• The Japan Securities Clearing Corporation’s Exemptive Order from Registration as a Derivatives Clearing Organization (Joint Trades Letter)?

• Additional Comments on NASAA’s Re-proposal of Revisions to its Model Rule (SIFMA Letter)?

• Form PF; Reporting Requirements for All Filers and Large Hedge Fund Advisers (Joint Trades Letter)?

• Call for Evidence: Submission from the British American Finance Alliance (BAFA Letter)?

• Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders, Final Rule (SIFMA Letter)?

• Notice of Partial Amendment No. 1 to Proposed Rule Change to Adopt the FINRA Rule 6500 Series (SIFMA and SIFMA AMG Letter)?

• Targeted Consultation on the Functioning of the EU Securitization Framework (SIFMA AMG Letter)?

• Proposed Amendments to FRAP 29 (Amicus Curiae Briefs) (SIFMA Letter)?

• Ongoing Data Collection of Non-Centrally Cleared Bilateral Transactions in the U.S. Repurchase Agreement Market, 12 CFR Part 1610 (SIFMA AMG Letter)?

• Security Requirements for Restricted Transactions Under Executive Order 14117 (SIFMA, FIA and IIB Letter)?

• Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by Countries of Concern or Covered Persons (SIFMA, FIA and IIB Letter)?

• Short Position and Short Activity Reporting by Institutional Investment Managers (Joint Trades Letter)?

• Notice of Proposed Rulemaking: Unsafe and Unsound Banking Practices - Brokered Deposit Restrictions (SIFMA Letter | Press Release | Joint Trades Letter)?

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Amicus Briefs:?

• Properties of the Village v. FTC (SIFMA Brief)?

• Nasdaq and Cboe v. SEC (SIFMA Brief)?

• Hunt v. PwC (SIFMA Brief)?

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Resources:?

• US Treasury Central Clearing: Industry Considerations Report (Report | Press Release | Briefing | FAQs)?

• Asset Management Fundamentals (SIFMA AMG)?

• Regulated Settlement Proof of Concept (Report | Press Release)?

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Newsroom:?

• SIFMA Statement on Confirmation of Treasury Secretary Bessent (Statement)?

• SIFMA Statement on Recission of SEC Staff Accounting Bulletin 121 (Statement)?

• SIFMA Statement on Trump-Vance Inauguration (Statement)?

• SIFMA Recommends Early Market Close on January 9, 2025, for the National Day of Mourning in Honor of Former President Carter (Press Release | Unscheduled Market Close Matrix)?

• SIFMA Statement on Amendment to the CAT NMS Plan (Statement)?

• SIFMA Issues 2025 and 2026 Fixed Income Recommendations for Full & Early Holiday Closes in the U.S., U.K., and Japan (Press Release)?

• Urgent Action Required: 5 Unresolved Issues in Treasury Central Clearing Rules (Blog)?

• Capitol Account Q&A: SIFMA CEO on the Financial Policy, Regulatory Landscape (Blog)?

• SIFMA Economist Roundtable Survey Forecasts Continued Economic Growth, Rate Cuts, and Declining Inflation in 2025 (Press Release | Survey)?

• The SIFMA Podcast: Considerations to Prepare for US Treasury Clearing (Podcast)?

• SIFMA Statement on Issuance of Revised No-Action Relief for SEC Rule 15c2-11 (Statement)?

• No, Risk Reduction by Banks Will Not Cause the Next Crisis (Blog)?

FEATURED CONTENT?

Highlights from SIFMA’s 2025 State of the Industry Briefing?

At SIFMA's recent State of the Industry Briefing, our leadership recapped key trends in the capital markets and shared our outlook for 2025, including an overview of SIFMA’s priorities on behalf of our members for the year ahead.?

In this post, SIFMA President and CEO Kenneth E. Bentsen, Jr. uncovers highlights related to both market performance and policy developments, including:?

• The shifting policy and regulatory landscape;?

• The Treasury Clearing mandate; and?

• The successful move to a T+1 settlement cycle.?

TOP 5 RESOURCES?

1. 2025 Capital Markets Outlook?
2. Market Practices & Model Documentation?
3. Capital Markets Fact Book?
4. The Primer Series by SIFMA Insights?
5. Market Metrics & Trends – December 2024?

CONNECT WITH C&L?

The SIFMA C&L Society is a community of exceptional compliance and legal professionals from across the financial services industry. Visit us at www.sifma.org/cl, email us at [email protected] and visit our Showcase page on LinkedIn.?