SIFMA provided comments to the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority’s (FINRA) proposed changes to rules relating to payments to unregistered persons.

SIFMA has long supported enhanced clarity in the rules applicable to dealings with unregistered persons, and believes that FINRA has thoughtfully developed and proposed revisions to its rules that reflect a cohesive vision of applicable regulatory framework related to payments of commissions or fees derived from a securities transaction to unregistered persons.

However, SIFMA believes that some aspects of the proposal would benefit from additional guidance, and notes that certain interpretive challenges remain in the Proposal with respect to the foreign finders exception, for which further guidance is necessary to enact a final rule that is efficient and effective in accomplishing the stated policy goals.