FINRA Reporting Requirements

SIFMA’s Self-Regulation and Supervisory Practices Committee provides comments to the Financial Industry Regulatory Authority (FINRA) on reporting requirements, FINRA Regulatory Notice 08-71. We recommend first that with respect to proposed FINRA Rule 4530(a)(3), FINRA incorporate the guidance in NYSE Information Memo 06-11 (IM 06-11) regarding reporting of internal conclusions of violative conduct that would not otherwise be reportable under proposed Rule 4530(a)(2). Second, we recommend that FINRA use this proposal as an opportunity to eliminate duplicative reporting requirements. Third, that the calculation of monetary thresholds under proposed Supplementary Material .06 exclude attorneys’ fees and interest.