Letters

FINRA’s Proposal on Disclosure and Reporting Obligations

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Financial Industry Rulemaking Authority’s (FINRA’s) proposed rule change to Rule 2243 (the Proposal), Disclosure and Reporting Obligations Related to Recruitment Practices, File Number SR-FINRA-2014-010; Release No. 34-71786.

SIFMA supports the underlying goal of the Proposal – to foster investor protection by requiring broker-dealers to disclose certain potential conflicts of interest that may arise in connection with a registered representative’s receipt of recruiting related bonus payments.

SIFMA’s comments on the Proposal focus on various operational challenges that SIFMA believes have not been fully considered and may adversely impact firms’ ability to efficiently and cost effectively implement the Proposal.

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