Trading Ahead of Research Reports

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a final rule on trading ahead of research reports, Financial Industry Regulatory Authority (FINRA) Rule 5280, Release No. 34-58905; File No. SR-FINRA-2008-54.  SIFMA generally agrees with the proposed rule, but proposes a clearer definition of the term “research report”, and confirmation that certain provisions of the proposed rule are not meant to (i) limit or restrict communications between sales and trading personnel and research analysts concerning the analysts’ published views; or (ii) require that such communications must be specially pre-cleared or monitored, so long as appropriate policies and procedures are in place to restrict the sharing of information concerning the timing or content of unpublished research reports.