Conflicts Involving the Preparation & Distribution of Debt Research Reports

SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on a proposal to apply objectivity standards and disclosure requirements to the publication and distribution of debt research reports, FINRA Regulatory Notice 12-09.  SIFMA has concerns about certain aspects of the Proposed Rule. In particular, SIFMA believes several areas should be modified or clarified including: the definition of “Debt Security” and “Research Report,” and prohibitions on pre-publication review of debt research reports.