The Securities Industry Association (SIA)* provides comments to the Securities Exchange Commission (SEC) on Amendment No. 2 to proposed rule changes by the New York Stock Exchange (NYSE) and the National Association of Securities Dealers, Inc. (NASD) relating to research analyst conflicts of interest, File Nos. SR-NYSE-2002-49 and SR-NASD-2002-154. SIA suggests alternatives to the requirement to disclose in research reports if a broker-dealer or its affiliates has received any compensation from the subject company in the past year and to the provision regarding disclosure of whether a subject company was a “client” of the broker-dealer in the past 12 months. SIA also has concerns of the record-keeping requirement for communications with the media proposed by the NYSE and some of the proposed implementation schedules.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.