Debt Research Reports

SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on FINRA’s Concept Proposal to identify and manage conflicts involving the preparation and distribution of debt research reports, FINRA Regulatory Notice 11-11.  Currently, debt research is subject to the Securities and Exchange Commission’s (SEC’s) Regulation Analyst Certification requirements and FINRA rules for communications with customers. For almost a decade, FINRA’s content standards have meant that institutional research and retail research for debt securities are subject to basic content standards, with additional requirements applying to retail research.  While FINRA’s content standards have worked well over the years, both SIFMA and, before SIFMA, The Bond Market Association (TBMA) have been active in advocating additional standards for debt research.  SIFMA responds to specific items for which FINRA has solicited comments, requests clarification regarding certain proposed provisions, and discusses concerns about certain aspects of the Concept Proposal.