VIA ELECTRONIC SUBMISSION

Jennifer Piorko Mitchell
Office of the Corporate Secretary
FINRA
1700 K Street, NW
Washington, DC 20006-1506

Re: Regulatory Notice 25-04: Rule Modernization

Dear Ms. Piorko Mitchell,

SIFMA¹ submits comments in response to Regulatory Notice (RN) 25-04.² We appreciate FINRA’s commitment to continuous improvement and welcome this effort to modernize and update its regulatory requirements applicable to broker-dealers and associated persons, as well as working with other regulators whose requirements are applicable to them, including the SEC, to fully realize its goal.

SIFMA provides a non-exhaustive list of topics and rules below that is responsive to FINRA’s request and a brief explanation for the action requested. This list includes FINRA rules and requirements as well as certain non-FINRA requirements appliable to broker-dealers that we believe should be amended and/or repealed. SIFMA believes that addressing these topics could result in reduced burdens, costs, and confusion, and greater opportunities for investors. We have prioritized the topics into two categories to denote the importance or urgency of these issues for our members: 1) high priority and 2) other priorities.

SIFMA appreciates your consideration of our comments and would be pleased to discuss them in detail and answer any questions you may have.

Sincerely,

Bernard V. Canepa
Managing Director and Associate General Counsel

1. SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org. [↩]
2. Regulatory Notice 25-04 (Mar. 12, 2025), https://www.finra.org/sites/default/files/2025-03/Regulatory-Notice-25-04.pdf [↩]