SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) regarding FINRA’s Regulatory Notice 09-70, which replaces and revises the existing rules governing registration and qualification requirements. SIFMA recommends to eliminate the proposed forfeiture and tolling measures contained in Rule 1210 (c), and instead replaced with a more straightforward ten-year license retention period for all Retained Associates, regardless of movement in and out of the broker-dealer. SIFMA also requests that FINRA modify or clarify various terms and requirements within Proposed Rules 1210 and 1230 to more accurately define the scope and application of these new rules.