FINRA Rules Governing Communications with the Public

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed consolidated Financial Industry Regulatory Authority (FINRA) rules governing communications with the public, SR-FINRA-2011-035.  Specifically, FINRA is proposing to adopt new FINRA Rules 2210 (Communications with the Public), 2212 (Use of Investment Companies Rankings in Retail Communications), 2213 (Requirements for the Use of Bond Mutual Fund Volatility Ratings), 2214 (Requirements for the Use of Investment Analysis Tools), 2215 (Communications with the Public Regarding Security Futures), and 2216 (Communications with the Public About Collateralized Mortgage Obligations [CMOs]) for the new FINRA consolidated rulebook, based in part on existing NASD Rules 2210 and 2211 and NASD Interpretive Materials 2210-1 and 2210-3 through 2210-8.  While substantial progress has been made on the proposed consolidated rules, SIFMA remains concerned about various provisions in proposed FINRA Rule 2210 and its supplementary material, and offers its observations and recommendations for the proposals.