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The SEC Shows That It's Never Too Late To Correct Some Mistakes
Monday, February 5, 2018

In 1997, the Securities and Exchange Commission adopted revisions to forms and schedules filed under the Securities Act of 1933, the Securities Exchange Act of 1934, related provisions of the Investment Company Act of 1940 and the Public Utility Holding Company Act of 1935 (RIP), and the Trust Indenture Act of 1939, to eliminate the portion of those forms that requests filers who are natural persons to furnish their Social Security numbers. 

For reasons not explained, the SEC inadvertently omitted the removal of the second of two references to Social Security numbers in the instructions to Form MSD. I had to look up Form MSD.  It is the form used to apply for registration as a municipal securities dealers.  I don't know whether it was indifference or ignorance, but applicants continued to use the form for two decades, notwithstanding the erroneous reference.  

Now, I'm pleased to report that the SEC has made things right.  Last week, it amended Instruction M to Form MSD by removing from the end of the third sentence the text “; social security numbers, if furnished, will be used only to assist the Commission in identifying applicants and, therefore, in promptly processing applications”.

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