MSRB Comments on the SEC’s Proposed Regulation Systems Compliance & Integrity

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The MSRB stated its support for the establishment of requirements relating to key systems of SCI entities that are critical to the maintenance of fair and orderly securities markets. But the MSRB also believes that there are a number of elements within proposed Regulation SCI that should be clarified or modified. Further, the MSRB believes that the scope of SCI systems subject to Regulation SCI should be more narrowly tailored or, in the alternative, that the implementation of proposed Regulation SCI should be staged in multiple phases depending on the type of SCI system and related SCI security system. Moreover, the MSRB believes that the processes envisioned under proposed Regulation SCI should be streamlined and that a broader and more flexible set of standards for the purposes of certain safe harbors be adopted.

To that end, the MSRB offered comments, observations, and implementation timeframes on the following rules:

  • Rule 1000(a)
  • Rule 1000(b)(3)
  • Rule 1000(b)(9)
  • Rule 1000(b)(1)(i)
  • Rule 1000(b)(4)
  • Rule 1000(c)
  • Rule 1000(b)(1)(ii)
  • Rule 1000(b)(5)
  • Rule 1000(d)
  • Rule 1000(b)(2)(i)
  • Rule 1000(b)(6)
  • Rule 1000(e)
  • Rule 1000(b)(2)(ii)
  • Rule 1000(b)(7)
  • Rule 1000(f)
  • Rule 1000(b)(2)(iii)
  • Rule 1000(b)(8)

 

See: MSRB Comment Letter S7-01-13.