MFA and AIMA Submit Comments on Proposed SEC Regulation SCI

MFA and AIMA submitted comments to the Securities and Exchange Commission (SEC) on its proposed Regulation Systems Compliance (“Reg SCI”) and Integrity.  In the letter, MFA and AIMA express support for the policy goals behind Reg SCI and for requiring SCI Entities to have policies, procedures and controls to ensure that their systems have levels of capacity, integrity, resiliency, availability, and security to maintain their operational capacity.  MFA and AIMA make a few recommendations to clarify the scope and help reduce the burden of the proposed regulation so that Reg SCI will not impair competition or innovation in our markets.  MFA and AIMA also emphasize that an important distinction needs to be made between market utilities and general market participants, and that the proposed regulation should only apply, as proposed, to market utilities.