Comment Letters

6/2/15 - FINRA Comment Letter to SEC regarding File No. S7-05-15 Proposed Rule Regarding Exemption for Certain Exchange Members

12/20/13 - FINRA Comment Letter to SEC regarding File No. 4-668 – Proposed National Market System Plan Governing the Process of Selecting a Plan Processor and Developing a Plan for the Consolidated Audit Trail

7/8/13 - FINRA Comment Letter to SEC regarding File No S7-01-13 – Regulation Systems Compliance & Integrity (Regulation SCI)

9/28/12 - Joint SRO Comment Letter to the SEC Regarding File No. 4-652 – SEC Technology and Trading Roundtable

2/17/11 - FINRA Comment Letter to the CFTC Regarding RIN No. 3038-AD08 – Real-Time Public Reporting of Swap Transaction Data

1/28/11 - FINRA Comment Letter to the SEC Regarding Regulation SBSR – Reporting and Dissemination of Security-Based Swap Information

11/2/10 - FINRA Comment Letter to the SEC Regarding Commission Study on Enhancing Investment Adviser Examinations Mandated by Section 914 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010

8/25/10 - FINRA Comment Letter to the SEC Regarding File No. 4-606, Study Obligations of Brokers, Dealers and Investment Advisers

8/9/10 - FINRA and NYSE Euronext Comment Letter to the SEC regarding file No. S7-11-10, Proposed Rule on Consolidated Audit Trail

8/9/10 - FINRA Comment Letter to SEC regarding File No. S7-11-10, Proposed Rule on Consolidated Audit Trail

4/23/10 - FINRA Comment Letter to SEC regarding File No. S7-02-10, Concept Release on Equity Market Structure

3/25/10 - FINRA Comment Letter to SEC regarding File No. S7-03-10, Risk Management Controls for Brokers or Dealers with Market Access

9/2/08 - FINRA Comment Letter to SEC regarding File No. S7-16-08, Exemption of Certain Foreign Brokers or Dealers

8/11/08 - FINRA Comment Letter to SEC regarding File No. S7-14-08; Proposed Changes to Definition of Equity Indexed Annuities and Certain other Insurance Contracts

5/12/08 - FINRA Comment Letter to SEC regarding File No. S7-06-08; Release Nos. 34-57427; IC-28178; IA-2712--Notice of Filing of Proposed Rule Change to Amend Regulation S-P. 

11/27/07 - FINRA Comment Letter to SEC regarding Proposed National Market System Plan (SEC File Nos. 4-533 and 4-534) 

8/29/07 -  FINRA Comment Letter to SEC regarding File No. SR-NASDAQ-2007-001, Notice of Filing of Proposed Rule Change as Modified by Amendment No. 2 to Amend Nasdaq’s "Clearly Erroneous" Rule.

4/19/07 - NASD Comment Letter to SEC regarding File No. S7-22-06, Definition of Terms and Exemptions Relating to the "Broker" Exceptions for Banks.

2/16/06 - NASD Comment Letter to SEC regarding File No. SR-NYSE-2005-77, Notice of Filing of Proposed Rule Change and Amendment Nos. 1, 2, 3, 4, 5 and 6 Relating to the Exchange's Business Combination with Archipelago Holdings, Inc.

4/4/05 - NASD Comment Letter on Proposed Rule:

Certain Broker-Dealers Deemed Not to Be Investment Advisers, Securities Exchange Act Release No. 50980; File No. S7-25-99

Certain Broker-Dealers Deemed Not To Be Investment Advisers
Release Nos. 34-50980; IA-2340; File No. S7-25-99

3/31/05 - NASD Comment Letter to SEC regarding Investment Company Act Release No. 26778 (March 1, 2005) (the "Supplemental Request for Comment") 

3/15/05 - NASD Comment Letter on Concept Release:
Concept Release Concerning Self-Regulation -- File No. S7-40-04

SEC Concept Release Concerning Self-Regulation

Release No. 34-50700; File No. S7-40-04

3/8/05 - NASD Comment Letter on Proposed Rule:
Notice of Proposed Rulemaking Concerning Governance,
Administration, Transparency, and Ownership of Self-Regulatory Organizations -- File No. S7-39-04

SEC Rule Proposal:

Fair Administration and Governance of Self-Regulatory Organizations; Disclosure and Regulatory Reporting by Self-Regulatory Organizations; Recordkeeping Requirements for Self-Regulatory Organizations; Ownership and Voting Limitations for Members of Self-Regulatory Organizations; Ownership Reporting Requirements for Members of Self- Regulatory Organizations; Listing and Trading of Affiliated Securities by a Self- Regulatory Organization -- File No. S7-39-04

2/11/05 - NASD Comment Letter on Proposed Rule:

Certain Broker-Dealers Deemed Not to Be Investment Advisers, Securities Exchange Act Release No. 50980; File No. S7-25-99 ("Proposing Release")

Certain Broker-Dealers Deemed Not To Be Investment Advisers

Release Nos. 34-50980; IA-2340; File No. S7-25-99

5/4/04 - NASD Comment Letter to SEC regarding disclosure for transactions in certain mutual funds and other securities.

6/20/03 - NASD Comment Letter - SEC Release No. 34-47849 (File No. S7-11-03)