House Committee to Consider 15c2-11 Fix Bill
December 16, 2025
The House Financial Services committee will consider legislation that would permanently exempt fixed-income securities from unnecessary and duplicative information requirements under SEC Rule 15c2-11.
- The bill H.R. 3959, the Protecting Private Job Creators Act, will be considered by the full committee this week.
- Click here for more background on the 15c2-11 issue for CMBS.
Why it matters: The SEC has issued exemptive relief and a no-action letter for public and private fixed-income securities after a 2021 staff interpretation said the rule, originally finalized in 1971, required broker-dealers to verify certain public information.
- CREFC continues to seek a permanent solution that clarifies the so-called penny stock rule does not apply to fixed-income securities, as future SEC leaders could easily rescind the exemptive relief and no-action letter.
- In June, Congressman Troy Downing (R-MT-02) and Congressman Cleo Fields (D-LA-06) introduced H.R. 3959, the Protecting Private Job Creators Act, which would exempt all fixed-income securities, including public fixed-income securities and 144A bonds.
- The legislation would provide a statutory basis for relief. The SEC could also conduct a rulemaking to clarify the fixed-income treatment.
What they’re saying: CREFC and 10 other trade organizations endorsed the legislation this summer and urged Congress to pass it.
Contact Sairah Burki (sburki@crefc.org) or David McCarthy (dmccarthy@crefc.org) with questions.