February 16, 2021

VIA Electronic Mail: [email protected]

Jennifer Piorko Mitchell
Office of the Corporate Secretary
FINRA
1735 K Street, NW
Washington, DC 20006-1506

Re: Regulatory Notice 20-42: FINRA Seeks Comment on Lessons from the COVID-19 Pandemic

Dear Ms. Mitchell:

The Securities Industry and Financial Markets Association (“SIFMA”)1 submits this letter to the Financial Industry Regulatory Authority Inc.’s (“FINRA”) request for public comment in light of lessons learned from firms’ experiences from the COVID-19 pandemic.2 We welcome this opportunity to share with FINRA the concerns and recommendations of our members as we all continue to weather the current health crisis and assess the potential takeaways for the financial industry.

SIFMA and its members would like to give their thanks to FINRA and its staff for their extraordinary efforts during the COVID-19 pandemic. FINRA has been an outstanding partner in coordinating with the industry and responding to the challenges presented by COVID-19. As we continue to navigate these uncertain times, we anticipate our engagement with FINRA will continue to be fruitful as we establish a new normal and FINRA determines how to regulate in a post-COVID-19 world.

Although the introduction of vaccines for COVID-19 provides promise for the future, in many respects and localities, the pandemic is continuing to worsen.3 Firms are still wrestling with the operational changes triggered by the pandemic and evaluating the short-term and longterm impacts. As such, our comments provided in this letter are preliminary and subject to
refinement as the pandemic runs its course and a new normal manifests itself more clearly.