SIFMA strongly urges the Commission not to move forward with the proposed framework, and instead consider more appropriate ways to address potential risks related to the use of PDA-like technologies.

“The Proposed Rules would impose unreasonable and unworkable requirements on brokers and advisors and would limit their ability to use technology to provide valuable information and services to their clients,” said SIFMA President and CEO Kenneth E. Bentsen, Jr in the letter. “These impractical limitations would harm market efficiency, competition, and investors.”

SIFMA and SIFMA AMG identified the following areas of concern:

The existing regulatory regime for investor communications by brokers and advisers is robust, reasonable, and effective, and the Commission has not shown any evidence or reason to justify new rules for their current or future uses of technology.

The Proposed Rules would require brokers and advisers to “eliminate or neutralize” conflicts of interest in all types of investor interactions and uses of technology, regardless of the existing framework or the nature of the relationship, and would burden many uses of technology that are unrelated to the Commission’s limited stated concerns.

The Proposed Rules would impose substantial and unjustified burdens which prevent a vast array of beneficial investor interactions and advisory practices.