SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority’s (FINRA’s) proposed rule change to NASD Rule 2340 involving per share estimated values of unlisted Direct Participation Programs (DPPs) and Real Estate Investment Trust (REITs) on customer account statements, SR-FINRA-2014-006 (Proposed Rule Change).

SIFMA fully supports FINRA’s efforts to design rules intended to improve customer protection and provide greater transparency in this area – such as the Proposed Rule Change’s acceptance of two types of valuation methodologies (net investment or independent valuation) as creating a “presumption” that the valuation(s) “have been developed in a manner reasonably designed to ensure that it is reliable.” However, SIFMA has concerns regarding the Proposed Rule Change.