The Arbitration Committee of SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposal by the Financial Industry Regulatory Authority (FINRA) relating to whistleblower claims in arbitration, File No. SR-FINRA-2011-067. To the extent the proposal simply aligns FINRA’s rules with Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), and other federal statutes that do not require parties to arbitrate whistleblower claims, SIFMA supports the proposed change.  However, SIFMA shares its concerns with certain language in the proposal, and offers recommendations that would clarify the scope and applicability of the proposed rule changes.