Comment Letter: FIF and STA Comments on Amended SEC Rule 606

While much progress has been made with respect to the industry’s implied understanding of the scope and breadth of data that the SEC Staff expects to be reported pursuant to Rule 606, there remain several open questions that the SEC is still considering.

FIF and STA strongly emphasize that the lack of: 1) written guidance; 2) adequate resolution of open questions; and 3) clarity pertaining to reporting look-through data is preventing industry stakeholders from moving forward with the implementation of Rule 606 in a manner that will provide end-customers with consistent and accurate data.

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