Regulatory Notice 12-09

FINRA Requests Comment on a Proposal to Identify and Manage Conflicts Involving the Preparation and Distribution of Debt Research Reports


Comment Period Expired: April 2, 2012

Executive Summary

FINRA seeks comment on a revised debt research conflicts of interest proposal that reflects changes based on comments to a concept proposal discussed in Regulatory Notice 11-11. The revised proposal maintains a tiered approach based on whether debt research is distributed to retail or institutional investors. Debt research distributed to retail investors would carry most of the same protections provided to recipients of equity research, while institutional investors could opt in to a framework that exempts such research from many of those provisions.


The text of the proposed rule can be found at


Questions concerning this Notice should be directed to:

  • Philip Shaikun, Associate Vice President, Office of General Counsel (OGC), at (202) 728-8451; and
  • Racquel Russell, Assistant General Counsel, OGC, at (202) 728-8363.
View Full Notice PDF 151 KB

The views, expressions, findings and opinions expressed in the comments on this Web page are solely those of the author(s) and FINRA accepts no responsibility for the content of the comments.

Comments By Date Received
Bond Dealers of America (PDF 319 KB) 4/2/2012
Aidikoff, Uhl & Bakhtiari (PDF 325 KB) 4/2/2012
Alliance in Support of Independent Research (PDF 237 KB) 4/2/2012
SIFMA (PDF 178 KB) 4/2/2012
Wulff, Hansen & Co. (PDF 322 KB) 4/5/2012
Romano Brothers & Co. (PDF 190 KB) 4/6/2012
Bingham McCutchen LLP (PDF 371 KB) 4/10/2012