12.9.21
SFA submitted a letter regarding the potential application of SEC Rule 15c2-11 to ABS, advocating that the information requirements under the rule are not germane to ABS. Existing time-limited no-action letter expires January 3, 2022. This rule regulates the publication of quotations in OTC markets and requires dealers to obtain and review issuer information prior to publishing quotations for the securities. SFA’s letter outlines our members’ deep concern that unintended consequences of Rule 15c2-11, if applied to ABS, will have a material and likely immediate adverse impact on market liquidity, resulting in direct harm to investors.