From SIFMA: “SEC should focus its resources on the most time-sensitive priorities, conduct more robust economic analysis that accounts for cumulative and overlapping effects before moving forward with the most problematic proposals, and prioritize transparency and public engagement”.
Substantive concerns are:
- Making it harder and/or more expensive for companies to raise capital and credit.
- Increasing regulatory compliance costs for American companies with uncertain benefits.
- Requiring rapid public disclosure of sensitive trading and position information of individual securities loans (within 15 minutes) and swap positions (within one day) that could reduce liquidity
Procedural concerns are:
- Circumventing the public notice-and-comment process.
- Using back-door rulemaking methods.
- Challenging long-standing legal precedent by applying rules retroactively.
SIFMA’s full commentary is found here.