SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on FINRA’s Concept Proposal that would require members to provide a disclosure statement to retail customers at or before the time the member commences a business relationship with such customer, and poses wide ranging questions about the nature and extent of this disclosure statement, FINRA Regulatory Notice 10-54.  SIFMA notes that its comments on the proposal are preliminary, and it anticipates supplementing the recommendations after further direction is provided by the Securities and Exchange Commission (SEC) in its study, or in response to any future specific rule proposal.