The Arbitration Committee, the Litigation Advisory Committee, and the Clearing Firms Committee of SIFMA provide comments to the Securities and Exchange Commission (SEC) on a Financial Industry Regulatory Authority (FINRA) proposal to amend Rules 12206 and 12504 of the Customer Code and Rules 13206 and 13504 of the Industry Code to address motions to dismiss, File No. SR-FINRA-2007-021.  SIFMA supports the goal of implementing rules targeted against spurious or bad-faith dispositive motions, but warns that there are a number of circumstances in which dispositive motions are appropriate. SIFMA offers recommendations that address this distinction.