SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority’s (FINRA’s) proposed interpretation to clarify the classification and reporting of certain securities to FINRA, File Number SR–FINRA–2013–039; Release No. 34-70482.

SIFMA believes that any guidance regarding the trade reporting of hybrid securities should be consistent with current market practice and allow those securities currently being reported to FINRA’s Trade Reporting and Compliance Engine (TRACE) to continue to be reported in that system.