*Letters

Personal Securities Transactions for & by Associated Persons

Published on:
June 8, 2009

SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on personal securities transactions for and by associated persons, Regulatory Notice 09-22. The Notice proposes to combine certain provisions of NASD Rule 3050 and Incorporated NYSE Rule 407, in addition to adopting new requirements in connection with personal trading activities of associated persons of member firms. SIFMA commends and supports FINRA’s efforts to consolidate, streamline and enhance existing FINRA and Incorporated NYSE rules governing personal trading activities of associated persons, however offers several amendments to the proposal. SIFMA believes these modifications would promote greater certainty regarding the accounts to which the rule applies, facilitate implementation of the new requirements, and alleviate many of the practical difficulties associated with the current proposal without detracting from the rule’s overarching policy goals.

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