SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposal that would codify the Financial Industry Regulatory Association’s (FINRA’s) amended Front Running Policy into new Rule 5270 and related Supplementary Material, SR-FINRA-2012-025.  SIFMA requests revisions and clarifications that seek to ensure, first, that broker-dealers retain the ability to engage in risk management and liquidity providing activities, both with respect to the specific transaction, and on a portfolio or similar basis, without violation of the proposed rule, and second, that firms have sufficient understanding of the proposal, and of the manner by which the proposed rule will coexist with related regulation and interpretive guidance.