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The IAA commented on the SEC’s re-proposal of amendments to Form 13F that (i) additional identifying information in Form 13F is not needed, (ii) the SEC could provide managers with flexibility to choose an alternative identifier to a CUSIP and should study holistically issues raised by requiring the use of licensed security identifiers, and (iii) the SEC should not make technical amendments to the well-established rounding conventions or how a security’s value is reported.
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