Securities Industry and Financial Markets Association

“Members sifma is a membership organization with the following classes of membership: broker-dealer members and asset manager members each broker-dealer member and asset manager member shall be entitled to vote with respect to the election of directors and other matters as may be submitted at any annual or other meeting of members entitled to vote. Associate members associate members shall not be entitled to vote with respect to the election of directors and other matters as may be submitted at any annual or other meeting of members entitled to vote, and shall not be eligible to serve as directors of the association.”

“Simfa is a membership organization and members have the following powers with respect to the governing body: broker-dealer members and asset manager members: each broker-dealer member and asset manager member shall be entitled to vote with respect to the election of directors and other matters as may be submitted at any annual or other meeting of members entitled to vote. Associate members: associate members shall not be entitled to vote with respect to the election of directors and other matters as may be submitted at any annual or other meeting of members entitled to vote, and shall not be eligible to serve as directors of the association.”

“Form 990 review process: the accounting department of the organization prepares the form 990 based on audited financial information. The draft form 990 is then reviewed by management and an external independent accounting firm. The audit and finance committee will review the final draft signed off by the external independent tax accountant. This review will be noted as an agenda item at an audit and finance committee meeting and will be duly noted in the minutes. The form 990 will be provided to all voting members of the board of trustees prior to submission to the irs.”

“Conflict of interest policy monitoring & enforcement: any employee in a position where his or her objectivity may be questioned because of an individual interest or family or personal relationship is required to notify the general counsel. Similarly, any employee aware of any transaction or relationship that could reasonably be expected to give rise to a personal conflict of interest is required to discuss the matter promptly with the general counsel. In addition, once every year, directors, officers, key employees, and all the employees of sifma are required to review a copy of the conflict of interest policy and to acknowledge in writing that he or she is compliant.”

“Process for determining compensation: the executive committee and the board acting as compensation committee hire consultants to review comparable packages for any new incoming ceo and officers. The consultant presents data for comparable positions both locally and nationally and the board's executive committee makes the final decision for the salary package. Currently, the ceo and coo have employment contracts which were approved by the executive committee and the board, governing annual salary increase and any bonus payments. For the remaining senior officers, the annual salary increase and bonus payments are determined by the annual evaluation process which must be approved by the board's compensation committee.”

“Availability of documents any request for governing documents, conflict of interest policy, and financial statements will be provided upon request at management's discretion.”

“Volunteers the number of volunteers was derived from sifma committee participants per the membership database.”

“Statement of program service accomplishments continued development and maintenance of best practices that are conducive to efficient conduct of the business and members of the organization: business continuity planning: www.sifma.org/bcp the financial services sector is identified as critical infrastructure by the u.s. Department of homeland security. Sifma and its member firms are dedicated to preparing for the risk of potential disruptions at both the firm and broader industry levels. Sifma plays a key role in coordinating the industry's response to incidents that can interrupt business and market functions and works to support firm-level bcp planning as well. Industry-wide business continuity test: www.sifma.org/bcp-test the industry-wide business continuity test is a critical exercise that highlights our industry's ability to operate through a significant emergency using backup sites, recovery facilities and backup communications capabilities across the industry. The test is supported by all major exchanges, markets and industry utilities. It involves test transactions for commercial paper, equities, options, futures, fixed income, settlement, payments, treasury auctions and market data. Sifma also facilitates a coordinated reg sci testing program which is completed in parallel with the sifma industry test. The test occurs on the same day as futures market testing coordinated by the futures industry association (fia), and on alternate years with canadian market participant test through the investment industry regulatory organization of canada (iiroc). Emergency crisis management command center: www.sifma.org/emergency in the event of an industry-wide incident, sifma convenes market participants; issues market close recommendations; and coordinates with market infrastructure providers, regulators and emergency personnel including the u.s. Department of the treasury, u.s. Department of homeland security, new york city office of emergency management, law enforcement and other official sector participants. Sifma organizes market response committees for the fixed income and equity markets to deliver an industry perspective in the event of disruptions to market infrastructure which may make unscheduled market closes or changes to settlement convention necessary. The committees have developed principles and objective decision making processes that recognize the significant improvements the industry has made with respect to business continuity and the expectations of regulators. These principles also reflect expectations for strong resiliency plans of critical financial market infrastructure and financial institutions. For fixed income, the committee has developed procedures to determine if it is necessary for sifma to recommend an unscheduled close in u.s. Fixed income markets. Cybersecurity: www.sifma.org/cybersecurity cyberattacks have become bolder and the threat higher. However, industry-wide efforts over the last decade have also evolved and grown to build effective cyber defenses. Sifma is actively engaged in coordinating the effort to support a safe, secure information infrastructure, with cybersecurity resources including best practices for insider threats, data protection principles, frameworks for penetration testing and more that provide security of customer information and efficient, reliable execution of transactions. We continually work with industry and government leaders to identify and communicate cybersecurity best practices for firms of all sizes and capabilities and educate the industry on evolving threats and appropriate responses. Sifma's cyber-resiliency efforts seek to: - promote enhanced regulatory harmonization to encourage a more effective allocation of cyber resources; - promote a robust industry-government partnership grounded in information sharing; - design exercises and industry tests to improve protocols for incident preparedness, response and recovery; and - use the lessons learned to refine indu”

“Statement of program service accomplishments advocacy: advocacy for issues of importance to its members: sifma brings together the shared interests of hundreds of broker-dealers, banks and asset managers. We advocate in support of effective and resilient capital markets. Sifma, on behalf of the financial services industry, engages with policymakers and regulators on a state, federal and global level through comment letters, testimony, studies and more. Sifma's goal is to ensure regulation is effective, balanced and consistent with its intended purpose, appropriately coordinated with other regulators and regulatory regimes, and avoids constraining capital formation and credit availability, or otherwise impeding the functioning of the markets and the individuals they serve. Treasury clearing: www.sifma.org/explore-issues/treasury-clearing the u.s. Treasury market is a bedrock of the global financial system. Today, there are $28 trillion of treasury securities outstanding. An average of over $910 billion is traded every day. New rules from the u.s. Securities exchange commission (sec), finalized in december 2023, will require most market participants to centrally clear cash and repo u.s. Treasuries. The rule change triggers a significant change in u.s. Treasury market structure and will have material impacts to market participants including broker-dealers, institutional investors, interdealer brokers, principal trading firms, and covered clearing agencies. Treasury cash clearing is required to go into effect by the end of 2025, and repo clearing is required to go into effect by june 30, 2026. The rule's timeline for implementation is aggressive and, as we near the first deadline, there are several significant open questions requiring formal guidance from regulators and other market participants to ensure a smooth transition to avoid unnecessary disruption in the treasury market. On behalf of our members, sifma is working to advance multiple workstreams and short-term deliverables that will set the stage for long-term implementation. These include development of market standard documentation, considerations for a firm's implementation, and necessary regulatory reforms. Prudential regulation: www.sifma.org/explore-issues/prudential-regulation/ prudential regulation requires banking organizations to prudently measure and manage risks, maintain adequate capital and liquidity levels, and have in place workable recovery and resolution plans. Our regulatory regime must account for the vital role the capital markets play in providing credit and financing the real economy, particularly as regulators consider the finalization of elements of the basel iii endgame and the gsib surcharge proposals. Those rules must be implemented in a manner that does not overly penalize banks' capital markets activities, which in turn could reduce liquidity in vital corporate and other funding markets, thereby hurting growth in the real economy. While bank capital requirements are an undoubtedly complex subject, there is no question that they have material impacts across the entire economy, affecting the ability of corporations, small businesses, governmental organizations, and consumers to fund their activities and manage all types of risks. Given these impacts, it's crucial that policymakers conduct sufficient analysis and oversight to ensure that bank capital requirements strike the appropriate balance between ensuring financial stability and macroeconomic growth. In this context, it is worth noting that the quantity of high-quality capital in the u.s. Banking system has increased three-fold since the global financial crisis, while total loss absorbing capacity has increased six-fold and liquidity levels have increased twelve-fold. Many independent studies have also found capital levels at the largest u.s. Banks to either be at or close to their "optimal" levels. And senior policymakers, including incoming treasury secretary scott bessent, former treasury”

“Sifma believes reasonable taxation and economic growth are not mutually exclusive and encourages policymakers to weigh impacts on growth and competitiveness when contemplating changes to the tax code. Many of sifma's members are global taxpayers as well, therefore international standards for raising revenue should consider the highly regulated nature of the financial services industry. Sifma's member firms are willing and prepared to help policymakers wade through the nuances and goals of their respective tax policy. Sifma believes taxes impact savings and investments for both individuals and businesses but remain necessary for government programs and support for domestic economic growth. We remain focused on international tax, capital gains and dividends, and protecting investors and savers from taxes that could hurt their savings and future retirement security. Aml & financial crime: www.sifma.org/explore-issues/aml-and-financial-crime/ an effective anti-money laundering program is a critical tool to fight financial crime and protect the integrity of the capital markets and global financial system. Anti-money laundering and financial crime professionals at broker-dealers have a unique role in combatting illicit finance. Never has there been a more dynamic and hopeful time for their efforts to protect and ensure the preeminence of the u.s. Capital markets. These professionals conduct substantial surveillance of fund movements in addition to transaction monitoring; they use know your customer (kyc) processes to look critically at sources of funds for their customers to identify suspicious account openings or account fundings; and they regularly analyze activity to identify illicit schemes that may be new to their firms. They file a significant number of suspicious activity reports (sars), providing critical leads for law enforcement investigations. The anti-money laundering act of 2020, which became law on january 1, 2021, is the most significant piece of aml related legislation since the usa patriot act of 2001. Sifma is committed to helping our members incorporate it into their risk-based programs, and we continue to engage with the treasury and other policymakers on new and modified requirements focused on mitigating financial crime risks across the securities industry. Broker-dealers and other financial institutions remain hopeful that regulators tasked with implementing the act remain faithful in their rulemakings to the aml act's purpose to modernize existing, cumbersome regulations that drain critical resources away from the most threatening illicit finance risks. It is critical that we also look to new business lines and products, including the marijuana industry and digital assets, which may present the same or additional illicit finance risks. Sifma has been at the forefront in assisting our members as they navigate this ever-changing and more complex landscape. In september 2024, the financial crimes enforcement network (fincen) of the u.s. Department of the treasury adopted a final rule applying anti-money laundering rules to investment advisers. Covered advisers would be required to implement a risk-based aml program, designate a person responsible for program administration, conduct training, arrange for independent program reviews, keep records relating to the transmittal of funds, and file suspicious activity reports. The rule is effective on january 1, 2026. While fincen tailored some requirements, others were not tailored to the unique nature of advisory businesses, creating unnecessary burdens that will need to be addressed through guidance or a revised rule. Fincen also proposed customer identification program (cip) requirements for investment advisers. Given cip is a predicate component to a well-functioning aml program and has not been finalized yet (as of early january 2025), fincen may need to extend the compliance date for the aml program rule to give advisers enough time to build out their programs. T”

“Statement of program service accomplishments conferences and events: https://events.sifma.org/ sifma conferences, events and webinars foster meaningful conversations about the capital markets and offer valuable professional development opportunities. Sifma annual meeting: capital markets finance the real economy, allocate risk, and support economic growth and financial stability. As the voice for the nation's securities industry, which delivers a broad range of financial services to clients including corporations, governments and individuals, sifma brings together hundreds of investment banks, wealth managers, broker-dealers and asset managers to advocate for their effectiveness and resiliency capital markets. Together, we are invested in america. Sifma compliance & legal society annual seminar: sifma's c&l annual seminar is the preeminent meeting place for compliance and legal professionals in financial services. Through education, our community protects our industry and further enhances its integrity. Operations conference & exhibition: for more than 50 years, sifma's operations conference & exhibition has gathered operations and technology leaders from across the capital markets ecosystem. Bringing together the buy and sell sides, we share perspectives, drive industry-leading initiatives, and explore cutting-edge solutions to accelerate change. The securities industry institute: the securities industry institute (sii) is the premier executive development program for securities industry professionals, hosted by sifma and wharton. For 74 years, sifma and the wharton school have partnered to develop the industry's high-potential rising leaders. Over three consecutive years sii participants learn from authorities on topics which develop leadership and managerial skills and enhance investment and industry knowledge. Sii's cost-effective talent development approach delivers actionable knowledge that is implementable today: the mission of the institute is to equip each participant with practical information, ideas, and answers directly applicable to their present and future responsibilities. Its customized curriculum is redesigned each year to reflect the needs of an ever-changing industry landscape.”

“During the year ended october 31, 2024, the association received an $8.15 million cash settlement related to litigation on an event cancellation insurance claim, which is reported as proceeds from legal settlement within the accompanying statement of activities for the year ended october 31, 2024. The association's board of directors reviewed the association's reserve level following the collection of these proceeds and authorized a $7 million member rebate applied to fiscal 2025 in the form of a one-time dues credit to full members.”

“Post-ret. Related changes other than net periodic post ret. Benefit cost -453,145. Proceeds from legal settlement 8,150,000.”