In December 2021, the Securities and Exchange Commission (SEC) released a no action letter that would apply Rule 15c2-11 to the fixed income market. Rule 15c2-11 initially targeted at over-the-counter (OTC) markets will now regulate the publication of quotations in fixed income markets by requiring dealers to obtain and review issuer information prior to publishing quotations for the securities. Given the extensive use of 144A issuance in structured finance and the publication of quotations for those deals, SFA launched the SEC 15c2-11 Task Force to establish a strategic response to the SEC. The Task Force will:

1. Develop an interpretation of the Rule and how the industry may be able to comply with the Rule
2. Discuss the potential implications of the Rule on the securitization industry and
3. Plan an advocacy effort with the SEC and Capitol Hill