Adoption of FINRA Rule 3220 & FINRA Rule 2070

SIFMA provides comments to the Securities and Exchange Commission (SEC) a proposed rule change relating to the adoption of FINRA Rule 3220 (Influencing or Rewarding Employees of Others) and FINRA Rule 2070 (Transactions Involving FINRA Employees) in the Consolidated FINRA Rulebook. The proposal would transfer National Association of Securities Dealers (NASD) Rule 3060 into the consolidated FINRA rulebook as new FINRA Rule 3220 without material change. SIFMA questions using the prescriptive requirements of NASD Rule 3060 instead of the principles-based approach FINRA usually uses in regard to business entertainment and gifts and gratuities.