Proposed Changes to Forms U4 & Form U5

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority (FINRA) rule to amend the Form U4 and Form U5 disclosure questions, Release No. 34-59-616; File No SR-FINRA-2009-008. SIFMA fully supports inclusion of the revised questions on the Form U4 and the timely filing of such information within Central Registration Depository system . They also agree that compliance with the new rule will place considerable administrative burdens on member firms, and therefore commend FINRA for its effort to afford firms additional time beyond the traditional 30 days to make the necessary disclosure amendments. SIFMA does not support, however, the implementation construct proposed in the rule. Rather, SIFMA firmly believes that the proposal presents significant practical challenges that make it extremely difficult for many firms to obtain and file the necessary information in the allotted timeframe.