Comment letters and papers

Follow updates and opinions submitted to corporate loan market regulators, legislators and policymakers by LSTA’s Policy & Advocacy team on behalf of our members and the industry overall.

Attached is the coalition letter in support of the FSOC Improvement Act.
Section 899, introduced as part of the One Big Beautiful Bill Act, is a proposed U.S. tax provision aimed at countering what are deemed “unfair foreign taxes” imposed on American companies.
LSTA, Inc. recently submitted comments on the recent consultation report titled “Leverage in Non-bank Financial Intermediation” which sets out the FSB’s analysis and proposed policy recommendations designed to address potential financial stability risks arising from leverage in non-bank financial intermediation (NBFI) (“Consultation”)....
Find below the final version of the joint trades letter on the SEC's Safeguarding Proposal that went to the SEC this morning....
September 11, 2023 VIA ELECTRONIC SUBMISSION Ms. Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street N.E. Washington, D.C. 20549-1090 RE: Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker- Dealers and Investment Advisers (SEC Rel. Nos. 34-97990; IA-6353; File No. S7-12-23, July 26, 2023) Dear Ms. Countryman:...
The LSTA submitted its second comment letter on the SEC’s recent Conflict in Securitizations Rule Proposal (the “Proposal”). Given the unreasonably short comment period offered by the SEC, the LSTA decided to split its response into three parts....
366 Madison Avenue, 15th Fl., New York, NY 10017 Tel: 212-880-3000 Fax: 212-880-3040 www.lsta.org March 27, 2023 VIA ELECTRONIC SUBMISSION Vanessa A. Countryman Secretary Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549-1090 Re: Prohibition Against Conflicts of Interest in Certain Securitizations (SEC Release No. 33- 11151; File No. S7-01-23; RIN 3235-AL04) Dear...
366 Madison Avenue, 15th Fl, New York, NY 10017 Tel: 212-880-3000 Fax: 212-880-3040 www.lsta.org March 1, 2023 Vanessa A. Countryman, Secretary Securities and Exchange Commission 100 F Street NE Washington, Dc 20549-1090 Re: Extension Request on Proposed Rule on Proposed Rule 192, Conflicts of Interest under Section 27B of Section 621 of the Dodd-Frank Act...
366 Madison Avenue, 15th Fl., New York, NY 10017 Tel: 212-880-3000 Fax: 212-880-3040 www.lsta.org February 14, 2023 Via Electronic Submission Ms. Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549 Re: File No. S7-26-22: Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N-PORT Reporting, Investment Company...
Please find below our Comment Letter on the U.S. Securities and Exchange Commission (“SEC” or “Commission”) under the Investment Advisers Act of 1940 (“Advisers Act”)...
LSTA appreciates the opportunity provided by the Board of Governors of the Federal Reserve System to comment on its recently proposed rule, Regulation Implementing the Adjustable Interest Rate (LIBOR) Act....
LSTA’s submission in response to the SEC’s proposed rule titled “Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices”....

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