FINRA Proposal Relating to Customer Account Statements

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Filing of Amendment No. 1 to proposed rule change to adopt Financial Industry Regulatory Authority (FINRA) Rule 2231 (Customer Account Statements) in the Consolidated FINRA Rulebook, Release No. 34-64969; File No. SR-FINRA-2009-28. FINRA proposes to exclude certain account activities from the proposed monthly account statement delivery requirement, clarify when written consent is required to send account statements and other account communications to third parties, and require that members continue to send statements and other account communications to customers, even when directed by the customer in writing to send such account information to a third party.

While noting substantial improvements have been made in the proposal, SIFMA remains concerned about various provisions in proposed FINRA Rule 2231. SIFMA shares their belief that certain of the changes required by the proposed Rule would impose significant additional costs on FINRA member firms that could outweigh the regulatory benefits of such changes, which have not been clearly articulated by FINRA in the proposal.

SIFMA provides supplemental comments to the SEC on this proposal on February 3, 2012.