Proposed Exemption for The Goldman Sachs Group, Inc. (Goldman) Located in New York, New York (Case No. D-12122)

SIFMA, a trade association representing broker-dealers and asset managers, opposes the proposed individual exemption because it imposes overly broad and unnecessary regulatory conditions. They argue that the exemption should instead utilize more tailored conditions similar to those issued prior to 2013, especially since the underlying disqualifying event was unrelated to the firm's core asset management activities.

Goldman Sachs supports the Department's proposal to simplify the exemption but requests specific modifications to reduce the number of required audits and broaden the definition of "Goldman Affiliated QPAMs." They argue that three existing audits are sufficient to demonstrate compliance and that the proposed definition of affiliates should include all current and future entities rather than just a specific list.