July 28, 2020

VIA ELECTRONIC MAIL

Vanessa Countryman
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: File Number SR–FINRA–2020–019: Proposed Rule Change to Temporarily Extend the Time to Complete Office Inspections under FINRA Rule 3110 (Supervision)

Dear Ms. Countryman,

The Securities Industry and Financial Markets Association (“SIFMA”)1 submits this letter to the Securities and Exchange Commission (the “Commission” or “SEC”) in response to the Financial Industry Regulatory Authority Inc.’s (“FINRA”) request for public comment on the temporary proposed new FINRA Rule 3110 (Supervision), Supplemental Material .16 (Temporary Extension of Time to Complete Office Inspections) (the “Temporary Rule”), which was filed for immediate effectiveness on July 7, 2020, relating to the on-site inspection of FINRA member firm office locations.2

I. Executive Summary

SIFMA and its members appreciate the opportunity to provide comments to the Commission on the Temporary Rule. Particularly in these trying times, it is important that regulators maintain an open dialogue with industry participants and flexibility in their approach to dealing with unforeseen consequences and uncertain outcomes of the COVID-19 pandemic environment. In furtherance of that open communication, SIFMA and its members ask that the Commission take into account the following considerations in connection with the Temporary Rule.

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum
for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the
U.S. regional member of the Global Financial Markets Association (GFMA).
2 FINRA, Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Temporarily Extend the Time
to Complete Office Inspections under FINRA Rule 3110 (Supervision), File No. SR-2020-019, 85 Fed. Reg. 40713 (July 7, 2020), https://www.finra.org/rules-guidance/rule-filings/sr-finra-2020-019.