Rule Change to Adopt FINRA Rule 2114 in the Consolidated FINRA Rulebook

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the notice of proposed rule change to adopt Financial Industry Regulatory Authority (FINRA) Rule 2114 in the Consolidated FINRA Rulebook, Release No. 34-59075. SIFMA suggests that FINRA maintain the current rule’s exemption for securities with a world wide average daily trading volume value of at least $100,000 during each of the six calendar months preceding the recommendation (see 2315 (e)(1)(E)).2 SIFMA believes that the removal of this exemption would require a due diligence review to be conducted for large, well-capitalized companies whose securities likely do not pose the type of risk that is intended to be addressed by the proposed rule.