SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on a FINRA proposal relating to markups, commissions and fees, FINRA Regulatory Notice 11-08.  SIFMA believes the proposal would modernize aspects of NASD Rule 2440 and IM-2440-1 by withdrawing both the “Five Percent Policy” and the proceeds provision. SIFMA believes that these and other changes – such as the transfer of existing NYSE Rule Interpretation 375/01 and NASD Rule 2430 – are sensible and appropriate in the context of FINRA’s rulebook consolidation efforts.  SIFMA shares concerns with the reduction in certainty that would follow the withdrawal of the “Five Percent Policy” unless accompanied by the simultaneous adoption of a modern alternative.