SECURITIES INDUSTRY AND FINANCIAL MARKETS ASSOCIATION
120 Broadway, New York, NY 10271 www.sifma.org

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Organizations Filed Purposes: SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industrys nearly 1 million employees, we advocate on legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.

SIFMA IS THE LEADING TRADE ASSOCIATION FOR BROKER-DEALERS, INVESTMENT BANKS AND ASSET MANAGERS OPERATING IN THE U.S. AND GLOBAL CAPITAL MARKETS. (SCH O)

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: Cybersecurity Cybersecurity is a top priority in the financial industry to ensure the security of customer assets and information and the efficient, reliable execution of transactions within markets. It is a shared objective that demands an integrated approach but is often complicated with an overlapping patchwork of regulation. In fact, no fewer than 11 federal agencies impose some form of cybersecurity requirements. This is in addition to individual state, SRO and jurisdictional requirements, as well as standards from the National Institute of Standards and Technology (NIST) and International Organization for Standardization (ISO). As a global industry, all market participants are interconnected and part of the same ecosystem and need to work together to protect the sector as a whole. This year, SIFMAs Quantum Dawn cybersecurity exercise went global. Together, financial institutions and the sector, as a whole, practiced and improved coordination and communications with key industry and government partners in order to maintain equity market operations in the event of a systemic cyber-attack. An effective and efficient cybersecurity policy is achieved most easily through harmonized, risk-based global standards that leverage extensive investments already made. The financial industry is committed to furthering the development of industry-wide cybersecurity initiatives that protect our clients and critical business infrastructure, improve data sharing between public and private entities and safeguard customer information. SIFMA is actively engaged in coordinating the effort to support a safe, secure information infrastructure, with cybersecurity resources which provide security of customer information and efficient, reliable execution of transactions. 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; see the Resources section of this book for our exercises, tests and other resources. Consolidated Audit Trail The SEC and the SROs continue to develop a comprehensive Consolidated Audit Trail (CAT) that would enable regulators to efficiently and accurately track all activity throughout the U.S. for equities and options trades. The CAT will allow regulators to link every order through its entire life cycle, including cancellations, modifications and executions, and the CAT database will link all orders with the account holder. As such, the CAT will enable regulators to conduct cross-market surveillance and market reconstruction by pulling together detailed trading data from all market centers. SIFMA has focused on concerns around risks related to the collection of Personally Identifiable Information (PII). SIFMA has engaged the SEC and the SROs for adjustments to the CAT to ensure adequate data protection and response, as well as restricting access to any submitted data to a strictly controlled environment. In October, the SROs filed for exemptive relief to remove certain PII - date of birth, SSN and account number - from CAT. Regulation Best Interest Implementation In June, the SEC voted 3-1 to adopt Regulation Best Interest. Reg BI requires broker-dealers to act in the best interest of their retail customers when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. The SEC also adopted Form CRS, a customer relationship summary. Finally, the SEC also issued interpretive guidance regarding the broker-dealer exclusion from the definition of investment advisers, and interpretive guidance regarding the standard of conduct for investment advisers. Since early 2009, SIFMA has consistently advocated for the establishment of a best interest standard for financial professionals when providing investment advice. For that reason, we have supported the efforts of the SEC to finalize comprehensive federal regulations that meaningfully raise the bar for broker-dealers when providing personalized investment advice about securities to retail customers. While well-intentioned, a patchwork of state-by-state approaches currently under discussion would undermine the new federal standard and also the interest of investor protection generally. To assist firms in understanding the various Reg BI and Form CRS requirements and their potential impacts, SIFMA partnered with Deloitte to develop a Reg BI implementation guide as a high-level framework for compliance and for assessing the rules potential impacts on firms. Senior Investor Protection It is vital that we are able to protect our senior investors from financial exploitation and the dangers of cognitive decline. SIFMA has been working with industry members, academics, and state and federal lawmakers to advance policies, practices, rules, regulations and statutes which enhance senior investor protections. A growing number of states have enacted senior investor protection laws that extend to broker-dealers, and several others are currently working to develop a similar path. Additionally, FINRA Rule 2165, permitting pauses on certain suspicious activity, and FINRA Rule 4512, requiring firms to request trusted contact information from certain clients, went into effect in February 2018. SIFMA continues to push for updated laws and regulations to get ahead of this emerging threat and better equip advisors - through regional workshops, toolkits and more - to protect their aging client base. This is an issue of increasing importance, and SIFMA looks to continue to lead on this issue, as it has for the past several years. Retirement Savings Legislation The retirement system in the United States is helping millions of Americans save for a secure retirement and maintain their standards of living as retirees. However, increased life expectancies, the uncertain future of Social Security benefits, higher health care costs, and low interest rates have increased the need for American workers to save more for retirement. Since its inception, the retirement system has become more effective and portable, leading to increased financial security for many Americans. Retirement savings plans also play an important role in the capital markets, as the contributions from these plans form a large amount of the capital invested in our financial markets. SIFMA is committed to increasing retirement security 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 encourages passage of retirement legislation that includes Open MEPs, increased incentives for small businesses to open plans, an increase in the RMD age, along with other provisions to improve access to retirement savings. Market Data Market data is information about current stock prices, recent trades, and supply-and-demand levels sold by national securities exchanges. Access to this information is essential to Americas world-leading capital markets, because all participants need timely and complete data to make informed trading decisions. Because exchanges control that information, they have enormous pricing power over the cost to access the data. At SIFMA, we believe market data reform should focus on promoting competition, supporting efficient markets, and providing a transparent and fair system for all investors. We continue to advocate for improvements to the SIP content, consistent with the recommendations the SEC is developing for proposals to changes to the SIP, and for the addition of competing SIPs to replace single-consolidator model. Housing Finance Reform The U.S. housing market is a critical piece of the general economy. It represents one-fifth of U.S. GDP and 35% of all private, non-financial debt in the country. In March 2019, a Presidential Memorandum was issued for Federal Housing Finance Reform that directed the U.S. Department of the Treasury and the Department of Housing and Urban Development (HUD) to conduct a broad review of our housing finance system, including the Government-Sponsored Enterprises (GSEs), Fannie Mae and Freddie Mac. In September, the Treasury and HUD released their housing finance reform plans. SIFMA supports the U.S. Administration and Congress working together to identify a permanent solution. Moving the GSEs out of the conservatorship of their regulator, the Federal Housing Finance Agency (FHFA), is a goal that we support but not without Congress taking the necessary action to address the need for an explicit government guarantee to ensure stable mortgage-backed securities (MBS). In their plans, the Administration outlined both legislative and administrative steps for reform of the GSEs

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. SIFMAS 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. A Financial Transaction Tax A financial transaction tax (FTT) is a levy on transactions of stocks, bonds and derivatives. While proposed as a means to raise funds or curb behavior, a financial transaction tax amounts to a sales tax on investors, savers and retirees. SIFMA is strongly opposed to a financial transaction tax, which raises costs to the issuers, pensions and investors who help drive economic growth, negatively impacting those saving for retirement, college or to buy a home by decreasing the amount of their savings. Moreover, major economies that have adopted such taxes have had overwhelmingly negative results, including reduced asset prices, trading moving to other venues, market dislocation and decreased liquidity. Past experience also suggests that it would raise less revenue than supporters often claim. The U.S. financial markets are the broadest and deepest in the world and this benefits American individuals and businesses in many ways. An FTT would substantially reduce market liquidity and impair the strength of the U.S. capital markets, a move that runs counter to strong, sustainable, and balanced growth, and the financial impact of such a tax is not just on markets. Tax Reform The Tax Cuts and Jobs Act (TCJA) significantly changed the way U.S. multinational foreign profits are taxed. Importantly, while the Global Intangible Low Tax Income (GILTI) regime was introduced as an outbound antibase erosion provision, it has not worked as envisioned. SIFMA supports final regulations that account for the unique concerns of financial services companies, results in the lowest possible effective tax rate on foreign earnings, mitigates the unintended consequences caused by interest expense allocation rules, and obtains reasonable treatment for US branches operating in foreign jurisdictions. Similarly, SIFMA also supports final regulations for Base Erosion and Anti-abuse Tax (BEAT) and tax-deductible interest that mitigate the impact of taxable interest on inter-company debt. This change would also better reflect the original intent of Congress. Finally, the TCJA imposed a new limitation on the deduction for business interest expense also known as the 163(j) limitation. SIFMA is in favor of final regulations that ensures interest is not imputed on certain types of uncleared swaps.

STATEMENT OF PROGRAM SERVICE ACCOMPLISHMENTS CONFERENCES AND SEMINARS SIFMA EVENTS FOSTER MEANINGFUL CONVERSATIONS ABOUT CRITICAL ISSUES IMPACTING OUR FINANCIAL MARKETS. BY PROVIDING RELEVANT AND LIVELY FORUMS, WE BRING TOGETHER INDUSTRY PROFESSIONALS WITH LEADING INDUSTRY EXECUTIVES AND EXPERTS, REGULATORS, AND POLICYMAKERS TO DISCUSS THE MOST PRESSING ISSUES FACING THE CAPITAL MARKETS TODAY. SIFMA ANNUAL MEETING SIFMAs Annual Meeting brings together the most influential voices shaping todays capital markets. Through candid one-on-one conversations and expert panel discussions, we assess challenges and gain insights into opportunities ahead. SIFMA COMPLIANCE & LEGAL SOCIETY ANNUAL SEMINAR For 52 years, SIFMAs C&L Annual Seminar has served as the preeminent event for compliance and legal professionals working in financial services. Throughout the three-day program, participants hear directly from industry leaders and regulators on the latest developments and trends and build professional relationships to collaborate better. With focused discussions by noted keynote speakers and subject matter experts, attendees will have the opportunity to earn CLE credit, including diversity and ethics credit, and network with peers. OPERATIONS CONFERENCE & EXHIBITION SIFMAs annual Operations Conference & Exhibition gathers operations, technology and regulatory leaders from across the securities industry for three days of discussions, addressing the industrys most critical priorities. THE SECURITIES INDUSTRY INSTITUTE The Securities Industry Institute (SII) is the premier executive development program for financial industry professionals, hosted by SIFMA and Wharton. For 69 years, SIFMA and The Wharton School at the University of Pennsylvania have partnered to develop the industrys high-potential, rising leaders. Each March, SII brings together 800 participants from across the industry with a world-class faculty on the campus of The Wharton School in Philadelphia. Participants meet for one week over three consecutive years to develop leadership and managerial skills, and enhance investment and industry knowledge. SIIs 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.

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