The Securities Industry Association (SIA)* and The Bond Market Association (TBMA)* provides comments to the National Association of Securities Dealers, Inc. (NASD) on proposed amendments to Conduct Rule 2720, NASD Notice to Members 06-52. Conduct Rule 2720 affects the manner in which NASD members may participate in the public distribution of securities in specific circumstances.  While the Associations, in general, support the proposal, they share observations and recommendations including how the rule should: 1) simplify the required compliance in certain circumstance; 2) further coordinate the rule with other NASD rules; and 3) take into account the global and diverse nature of modern financial instruments.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.