Amending NASD Rule 2220 Relating to Options Communications

The Equity Options Trading Committee of SIFMA provides comments to the Securities and Exchange Commission (SEC) on  a proposal that would amend the National Association of Securities Dealers (NASD) Rule 2220 – Options Communications with the Public, SR-FINRA-2008-013. SIFMA generally agrees with the proposal, including: (1) the elimination of the prior supervisory and (Financial Industry Regulatory Authority) FINRA pre-approval requirements for educational materials;  (2) clarification of standardized verse conventional option communication requirements; (3) and the alignment of Rule 2220 with the other NASD rules governing communications. SIFMA shares its observations and recommendations relating to the Options Disclosure Document (ODD) including the document be allowed to be presented via hyperlink, in order to save paper and to avoid e-mail issues.