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

Re: FINRA Retrospective Review on the Effectiveness and Efficiency of its Reporting Requirements Rule 4530 (Rule 4530)

Dear Ms. Mitchell,

The Securities Industry and Financial Markets Association (“SIFMA”)1 submits this letter to the Financial Industry Regulatory Authority (“FINRA”) to provide comments on the retrospective rule review of Rule 4530 (Reporting Requirements), as outlined in Regulatory Notice 20-02, to assess the effectiveness and efficiency of the requirement to report specified events to FINRA. SIFMA supports and appreciates the continued efforts of FINRA to enhance FINRA rules through the retrospective review process.

I. Executive Summary

SIFMA and its members ask that FINRA improve reporting requirements under Rule 4530 by (1) eliminating duplicative reporting requirements, (2) simplifying the manner in which member firms report, (3) clarifying aspects of the requirements, (4) modifying certain reporting requirements and related processes, and (5) modernizing the processes overall.

Moreover, with specific reference to Rule 4530(b), we ask FINRA to strongly consider adopting a more principles based approach to firm’s self-reporting obligations that would more effectively advance its mission of investor protection than the current rigid, rules-based approach SIFMA and its members believe that these improvements will lead to more efficient processes without impairing the efficacy of Rule 4530.