June 18, 2025

Submitted via email to: [email protected]
Jennifer Piorko Mitchell
Office of the Corporate Secretary
FINRA
1700 K Street, NW
Washington, DC 20006-1506

Re: FINRA Regulatory Notice 25-06: FINRA Requests Comment on Modernizing FINRA Rules, Guidance and Processes to Facilitate Capital Formation

Dear Ms. Mitchell:

The Securities Industry and Financial Markets Association (“SIFMA” or “we”)1 appreciates the opportunity to respond to the request for comment by the Financial Industry Regulatory Authority, Inc. (“FINRA”) in Regulatory Notice 25-06 (“Regulatory Notice 25-06”),2 which requests comments on its rules and related guidance governing (i) capital acquisition brokers and other limited purpose broker-dealers, (ii) research analysts and research reports, and (iii) capital raising, including the FINRA Corporate Financing Rules,3 in an effort to further facilitate capital formation. We note that SIFMA also previously provided comment letters dated August 7, 2023, in response to Regulatory Notice 23-09 and March 20, 2025, in response to Regulatory Notice 24-17.4