Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of Amendment No. 1 and Order Granting Accelerated Approval of a Proposed Rule Change, as Modified by Amendment No. 1, Relating to Amendments to the Discovery Guide and Rules 12506 and 12508 of the Code of Arbitration Procedure for Customer Disputes, 19155-19160 [2011-8200]
Download as PDF
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Federal Register / Vol. 76, No. 66 / Wednesday, April 6, 2011 / Notices
Separate Accounts after the 6% Contract
Enhancement is applied. Accordingly,
the asset-based charges applicable to the
Separate Accounts will be assessed
against the entire amounts held in the
Separate Accounts, including any 6%
Contract Enhancement amounts. As a
result, the aggregate asset-based charges
assessed will be higher than those that
would be charged if the Contract
owner’s contract value did not include
any Contract Enhancement.
6. Applicants submit that the
provisions for recapture of any Contract
Enhancement under the Contracts do
not violate Sections 2(a)(32) and
27(i)(2)(A) of the Act. Sections 26(e) and
27(i) were added to the Act to
implement the purposes of the National
Securities Markets Improvement Act of
1996 and Congressional intent. The
application of a 6% Contract
Enhancement to premium payments
made under the Contracts should not
raise any questions as to compliance by
the Insurance Companies with the
provisions of Section 27(i). However, to
avoid any uncertainty as to full
compliance with the Act, Applicants
request an order granting an exemption
from Sections 2(a)(32) and 27(i)(2)(A), to
the extent deemed necessary, to permit
the recapture of the 6% Contract
Enhancement under the circumstances
described in the Application, without
the loss of relief from Section 27
provided by Section 27(i).
7. Applicants state that Section 22(c)
of the Act authorizes the Commission to
make rules and regulations applicable to
registered investment companies and to
principal underwriters of, and dealers
in, the redeemable securities of any
registered investment company to
accomplish the same purposes as
contemplated by Section 22(a). Rule
22c–1 under the Act prohibits a
registered investment company issuing
any redeemable security, a person
designated in such issuer’s prospectus
as authorized to consummate
transactions in any such security, and a
principal underwriter of, or dealer in,
such security, from selling, redeeming,
or repurchasing any such security
except at a price based on the current
net asset value of such security which
is next computed after receipt of a
tender of such security for redemption
or of an order to purchase or sell such
security.
8. Applicants state that it is possible
that someone might view the Insurance
Companies’ recapture of the 6%
Contract Enhancement as resulting in
the redemption of redeemable securities
for a price other than one based on the
current net asset value of the Separate
Accounts. Applicants contend,
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16:52 Apr 05, 2011
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however, that the recapture of the 6%
Contract Enhancement does not violate
Rule 22c–1. The recapture of some or all
of the 6% Contract Enhancement does
not involve either of the evils that
Section 22(c) and Rule 22c–1 were
intended to eliminate or reduce as far as
reasonably practicable, namely: (i) The
dilution of the value of outstanding
redeemable securities of registered
investment companies through their
sale at a price below net asset value or
repurchase at a price above it, and (ii)
other unfair results, including
speculative trading practices. To effect a
recapture of a 6% Contract
Enhancement, the Insurance Companies
will redeem interests in a Contract
owner’s contract value at a price
determined on the basis of the current
net asset value of the Separate
Accounts. The amount recaptured will
be less than or equal to the amount of
the Contract Enhancement that the
Insurance Companies paid out of their
general account assets. Although
Contract owners will be entitled to
retain any investment gains attributable
to the 6% Contract Enhancement and to
bear any investment losses attributable
to the 6% Contract Enhancement, the
amount of such gains or losses will be
determined on the basis of the current
net asset values of the Separate
Accounts. Thus, no dilution will occur
upon the recapture of the Contract
Enhancement. Applicants also submit
that the second harm that Rule 22c–1
was designed to address, namely,
speculative trading practices calculated
to take advantage of backward pricing,
will not occur as a result of the
recapture of the 6% Contract
Enhancement. Because neither of the
harms that Rule 22c–1 was meant to
address is found in the recapture of the
Contract Enhancement, Applicants
assert that Rule 22c–1 should not apply
to the 6% Contract Enhancement.
However, to avoid any uncertainty as to
full compliance with Rule 22c–1,
Applicants request an order granting an
exemption from the provisions of Rule
22c–1 to the extent deemed necessary to
permit them to recapture the Contract
Enhancement under the Contracts.
9. Applicants also submit that
extending the requested relief to
encompass Future Contracts and Other
Accounts is appropriate in the public
interest because it promotes
competitiveness in the variable annuity
market by eliminating the need to file
redundant exemptive applications prior
to introducing new variable annuity
contracts. Applicants assert that
investors would receive no benefit or
additional protection by requiring
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19155
Applicants to repeatedly seek exemptive
relief that would present no issues
under the Act not already addressed in
the Application.
10. Applicants submit, for the reasons
stated herein, that their exemptive
request meets the standards set out in
Section 6(c) of the Act, namely, that the
exemptions requested are appropriate in
the public interest and consistent with
the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act and that,
therefore, the Commission should grant
the requested order.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–8081 Filed 4–5–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–64166; File No. SR–FINRA–
2010–035]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Amendment No. 1 and Order Granting
Accelerated Approval of a Proposed
Rule Change, as Modified by
Amendment No. 1, Relating to
Amendments to the Discovery Guide
and Rules 12506 and 12508 of the
Code of Arbitration Procedure for
Customer Disputes
April 1, 2011.
I. Introduction
On July 12, 2010, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (‘‘SEC’’ or
‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Exchange Act’’ or ‘‘Act’’) 1 and
Rule 19b–4 thereunder,2 a proposed rule
change to amend the Discovery Guide,
which includes Document Production
Lists, and to make conforming changes
to Rules 12506 and 12508 of the Code
of Arbitration Procedure for Customer
Disputes (‘‘Customer Code’’). The
proposed rule change was published for
comment in the Federal Register on
August 3, 2010.3 The Commission
received 55 comment letters on the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Exchange Act Release No. 62584 (July 28,
2010), 75 FR 45685 (August 3, 2010).
2 17
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proposed rule change.4 On February 8,
4 See comment letters submitted by Richard A.
Stephens, Esq., dated August 6, 2010 (‘‘Stephens
comment’’); Seth E. Lipner, Esq., Baruch College,
Member, Deutsch & Lipner, dated August 15, 2010
(‘‘Lipner comment’’); Leonard Steiner, Esq., dated
August 16, 2010 (‘‘Steiner comment’’); Robert C.
Port, Esq., Cohen Goldstein Port Gottlieb, LLP,
dated August 19, 2010 (‘‘Port comment’’); Steven M.
McCauley, Esq., dated August 19, 2010 (‘‘McCauley
comment’’); Steven B. Caruso, Esq., Maddox Hargett
& Caruso, P.C., dated August 20, 2010 (‘‘Caruso
comment’’); Diane Nygaard, Esq., dated August 20,
2010 (‘‘Nygaard comment’’); Ryan K. Bakhtiari, Esq.,
Aidikoff, Uhl and Bakhtiari, dated August 20, 2010
(‘‘Bakhtiari comment’’); Thomas R. Cox, Esq., Miller,
Canfield, Paddock and Stone, P.L.C., dated August
20, 2010 (‘‘Cox comment’’); Steven J. Gard, Esq.,
dated August 22, 2010 (‘‘Gard comment’’); John W.
Shaw, Esq., Berkowitz, Oliver, Williams, Shaw and
Eisenbrandt, dated August 23, 2010 (‘‘Shaw
comment’’); Stephen Krosschell, Esq., Goodman &
Nekvasil, P.A., dated August 23, 2010 (‘‘Krosschell
comment’’); David P. Neuman, Esq., Stoltmann Law
Offices, P.C., dated August 23, 2010 (‘‘Neuman
comment’’); Theodore A. Krebsbach, Esq.,
Krebsbach and Snyder, P.C., dated August 23, 2010
(‘‘Krebsbach comment’’); Eric G. Wallis, Esq., Reed
Smith LLP, dated August 23, 2010 (‘‘Wallis
comment’’); Herb Pounds, Jr., Esq., dated August 23,
2010 (‘‘Pounds comment’’); Alan S. Brodherson,
Esq., dated August 24, 2010 (‘‘Brodherson
comment’’); Joseph Terry, dated August 24, 2010
(‘‘Terry comment’’); Mark James, dated August 24,
2010 (‘‘James comment’’); Jonathan W. Evans, Esq.,
and Michael S. Edmiston, Esq., Law Offices of
Jonathan W. Evans & Associates, dated August 24,
2010 (‘‘Evans and Edmiston comment’’); G. Kirk
Ellis, Esq., dated August 24, 2010 (‘‘Ellis comment’’);
Jason R. Doss, Esq., The Doss Firm, LLC, dated
August 24, 2010 (‘‘Doss comment’’); Jenice L.
Malecki, Esq., Malecki Law, dated August 24, 2010
(‘‘Malecki comment’’); Frances Ruby, dated August
24, 2010 (‘‘Ruby comment’’); Carrie L. Chelko, Esq.,
Deputy General Counsel, Janney Montgomery Scott
LLC, dated August 24, 2010 (‘‘Janney comment’’);
Raymond W. Henney, Esq., Honigman Miller
Schwartz and Cohn LLP, dated August 24, 2010
(‘‘Henney comment’’); Jonathan Kord Lagemann,
Esq., dated August 24, 2010 (‘‘Lagemann
comment’’); Brian N. Smiley, Esq., Smiley Bishop &
Porter, LLP, dated August 24, 2010 (‘‘Smiley
comment’’); Stanley Yorsz, Esq., Buchanan Ingersoll
& Rooney PC, dated August 24, 2010 (‘‘Yorsz
comment’’); Dominick F. Evangelista, Esq., Bressler,
Amery & Ross, P.C., dated August 24, 2010
(‘‘Evangelista comment’’); Michael N. Ungar, Esq.,
Kenneth A. Bravo, Esq., Joseph S. Simms, Esq., and
Jill Y. Coen, Esq., Ulmer & Berne LLP, dated August
24, 2010 (‘‘Ulmer & Berne comment’’); Barry D.
Estell, Esq., dated August 24, 2010 (‘‘Estell
comment’’); Richard A. Lewins, Esq., dated August
24, 2010 (‘‘Lewins comment’’); Robert M. Rudnicki,
Esq., Vice President and Director of Litigation,
Raymond James & Associates, Inc., on behalf of
Raymond James Financial, Inc. and Raymond James
& Associates, Inc., dated August 24, 2010
(‘‘Raymond James comment’’); Lee H. Schillinger,
dated August 24, 2010 (‘‘Schillinger comment’’);
Paula D. Shaffner, Esq., Stradley Ronon Stevens &
Young, LLP, dated August 24, 2010 (‘‘Shaffner
comment’’); Kelly J. Moynihan, Esq., Keesal, Young
& Logan, dated August 24, 2010 (‘‘Moynihan
comment’’); Richard L. Martens, Esq., Jason S.
Haselkorn, Esq., Patricia M. Christiansen, Esq.,
Charles L. Pickett, Esq., Casey Ciklin Lubitz
Martens & O’Connell, dated August 24, 2010
(‘‘Casey Ciklin comment’’); Peter J. Mougey, Esq.,
Levin Papantonio Thomas Mitchell Rafferty &
Proctor, P.A., dated August 24, 2010 (‘‘Mougey
comment’’); Rob Bleecher, Esq., dated August 24,
2010 (‘‘Bleecher comment’’); Scott R. Shewan, Esq.,
President, Public Investors Arbitration Bar
Association, dated August 24, 2010 (‘‘PIABA
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16:52 Apr 05, 2011
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2011, the Commission received from
FINRA a Response to Comments and
Partial Amendment No. 1 to the
proposed rule change.5 The Commission
is publishing this notice and order to
solicit comment on Amendment No. 1
and to approve the proposed rule
change, as modified by Amendment No.
1, on an accelerated basis.
II. Description of Proposed Rule Change
and Summary of Comments
As described in Exchange Act Release
No. 62584,6 FINRA is proposing to
amend the Discovery Guide, which
includes Document Production Lists,
and to make conforming changes to
Rules 12506 and 12508 of the Customer
Code. Of the 55 comments received on
the initial proposal, 15 supported it
with modifications,7 36 opposed it,8 and
4 addressed particular aspects of the
proposal without expressing a position
comment’’); Bradford D. Kaufman, Esq., Greenberg
Traurig, P.A., dated August 24, 2010 (‘‘Kaufman
comment’’); William A. Jacobson, Esq., Associate
Clinical Professor, Cornell Law School, and
Director, Cornell Securities Law Clinic, dated
August 24, 2010 (‘‘Cornell Securities Law Clinic
comment’’); S. Lawrence Polk, Esq., Sutherland
Asbill & Brennan LLP, dated August 24, 2010 (‘‘Polk
comment’’); John R. Cronin, Vermont Securities
Director and Chair, NASAA Arbitration Project
Group, dated August 25, 2010 (‘‘NASAA
comment’’); Theodore M. Davis, Esq., dated August
25, 2010 (‘‘Davis comment’’); Eliot Goldstein, Esq.,
Law Offices of Eliot Goldstein, LLP, dated August
25, 2010 (‘‘Goldstein comment’’); Richard M. Layne,
Esq., dated August 26, 2010 (‘‘Layne comment’’);
Royal B. Lea, Esq., dated August 27, 2010 (‘‘Lea
comment’’); Keith L. Griffin, Esq., Griffin Law Firm,
LLC, dated August 27, 2010 (‘‘Griffin comment’’);
Patricia Cowart, Esq., Chair, SIFMA Arbitration
Committee, dated September 10, 2010 (‘‘SIFMA
comment’’); Gail E. Boliver, Esq., Boliver & Bidwell,
dated September 16, 2010 (‘‘Boliver comment’’);
Scott C. Ilgenfritz, Esq., Johnson, Pope, Bokor,
Ruppel & Burns, LLP, dated September 24, 2010
(‘‘Ilgenfritz comment’’); Matthew Farley, Esq.,
Drinker Biddle & Reath LLP, dated September 24,
2010 (‘‘Drinker Biddle comment’’); and Kathy A.
Besmer, dated November 6, 2010 (‘‘Besmer
comment’’).
5 See letter from Margo A. Hassan, Assistant Chief
Counsel, FINRA Dispute Resolution, to Elizabeth
Murphy, Secretary, Commission, dated February 8,
2011 (‘‘Response Letter’’). The text of the proposed
rule change and FINRA’s Response Letter are
available on FINRA’s Web site at https://
www.finra.org, at the principal office of FINRA, on
the Commission’s Web site at https://www.sec.gov,
and at the Commission’s Public Reference Room.
6 See note 3 supra.
7 See Caruso, Bakhtiari, Cox, Pounds, Doss,
Malecki, Smiley, Lewins, Raymond James, Mougey,
PIABA, Cornell Securities Law Clinic, SIFMA,
Boliver, and Ilgenfritz comments.
8 See Lipner, Steiner, Port, McCauley, Nygaard,
Gard, Shaw, Neuman, Krebsbach, Krosschell,
Brodherson, Terry, James, Evans and Edmiston,
Ellis, Ruby, Janney, Lagemann, Yorsz, Evangelista,
Ulmer & Berne, Estell, Schillinger, Shaffner,
Moynihan, Casey Ciklin, Bleecher, Kaufman,
NASAA, Davis, Goldstein, Layne, Lea, Griffin,
Drinker Biddle, and Besmer comments.
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on whether the Commission should
approve the proposed rule change.9
In its Response Letter, FINRA stated
that the initial proposed rule change
reflected several years of close
consultation with FINRA’s constituents,
including investor and industry
representatives, arbitrators, and
attorneys that handle investor claims at
securities arbitration clinics. FINRA also
stated that, because the Discovery
Guide, as amended by the initial
proposed rule change, was comprised of
language that was discussed at length
with these constituents and crafted to
balance the parties’ discovery needs
with the goal of keeping FINRA
arbitration efficient and cost effective,
FINRA was, for the most part, making
only limited further revisions to the
proposed rule change to provide
additional clarification and guidance.10
In addition, FINRA stated that, if the
Commission approves the proposed rule
change as amended, it would establish
a Discovery Task Force under the
auspices of FINRA’s National
Arbitration and Mediation Committee to
review substantive issues relating to the
Discovery Guide on an ongoing basis,
for the purpose of keeping the Discovery
Guide current as products change and
new discovery issues arise.11 FINRA
stated that it would convene the
Discovery Task Force approximately six
months after implementing the revised
Discovery Guide to allow practitioners
time to gauge the efficacy of the new
Discovery Guide.12
FINRA’s responses to comments and
changes to the proposed rule change
made by Amendment No. 1 are
described below.
A. Guide Introduction
1. Arbitrator Discretion
Commenters expressed concerns that
arbitrators may adhere strictly to the
Discovery Guide’s two lists of
documents (the first itemizing categories
of documents to be produced by firms
and their associated persons, and the
second itemizing categories of
documents to be produced by
customers—together, ‘‘Lists’’) when
making discovery decisions and may
not use the flexibility the Discovery
Guide provides to them.13 FINRA
responded that it wants arbitrators to be
aware of the flexibility they have when
9 See Stephens, Wallis, Henney, and Polk
comments.
10 Response Letter.
11 Id.
12 Id.
13 See Lipner, Krebsbach, Evans and Edmiston,
Shaffner, Bleecher, Griffin, Henney, NASAA, Yorsz,
Goldstein, SIFMA, and Drinker Biddle comments.
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asked to decide discovery disputes, and
therefore the initial proposal included
revisions to the introduction of the
Discovery Guide stating that arbitrators
may order production of documents not
appearing on the Lists, and that
arbitrators can order that parties do not
have to produce all items on the Lists
in a particular case.14 Further, these
revisions added guidance on how
arbitrators should handle objections
based on cost or burden of production.15
In addition to these changes, and in
response to commenters’ concerns,
FINRA has proposed changes to the
introduction to explain that arbitrators
must use their judgment in considering
requests for documents beyond those
contained in the Lists and may not deny
document requests on the grounds that
the documents are not expressly listed
in the Discovery Guide.16 FINRA stated
that, in addition to expanding the
language in the Discovery Guide, if the
SEC approves the proposed rule change,
FINRA would revise the Arbitrator’s
Reference Guide, which is posted on the
FINRA Web site, to include a discussion
on how arbitrators should use the new
Discovery Guide.17 FINRA also stated
that it would update its arbitrator
training materials to ensure that FINRA
makes arbitrators aware of the
revisions.18 In addition, FINRA stated
that it would offer training on the
revised Discovery Guide in a workshop
that FINRA would post as an audio file
on its Web site if the proposed rule
change, as amended, is approved.19
2. Business Models and Types of
Customer Claims
FINRA initially proposed adding
language to the introduction of the
Discovery Guide stating that parties and
arbitrators should recognize that not all
firms have the same business models
and that certain items on the Lists may
not be relevant in a particular case when
the firm’s business model (e.g., full
service firm, discount broker, or online
broker) is taken into consideration.20
Commenters requested that FINRA add
‘‘clearing firm’’ to the parenthetical
listing examples of business models.21
FINRA agrees that adding ‘‘clearing
14 Response
Letter.
15 Id.
4. Enforcing Document Production
Commenters raised concerns about
arbitrators not adequately enforcing the
Letter.
23 Id.
17 Id.
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3. Privilege
Several commenters raised concerns
that List items might require production
of privileged documents.29 One
commenter suggested that parties raise
objections based on unspecified or
unrecognized privileges.30 Based on
these comments, FINRA believes that
additional guidance on acceptable
grounds for assertions of privilege
would be helpful to parties and
arbitrators, and is proposing to add
language to the introduction stating that
parties are not required to produce
documents that are otherwise subject to
an established privilege, including the
attorney-client privilege and attorney
work product doctrine.31
22 Response
16 Id.
24 See
18 Id.
PIABA and Caruso comments.
Letter.
26 See note 3 supra.
27 See Yorsz and Martens comments.
28 Response Letter.
29 See Krosschell, Pounds, Evans and Edmiston,
Schillinger, PIABA, Polk, Layne, SIFMA, Drinker
Biddle, and Janney comments.
30 See Estell comments.
31 Id.
25 Response
19 Id.
20 See
note 3 supra.
SIFMA and Drinker Biddle comments. The
Drinker Biddle comment also asked FINRA to add
‘‘prime-brokerage firm’’ to the parenthetical. FINRA
believes that adding ‘‘clearing firm’’ to the
parenthetical will add sufficient clarity for the
Guide’s users and is not proposing to add ‘‘primebrokerage firm’’ at this time.
21 See
VerDate Mar<15>2010
firm’’ to the parenthetical would be
helpful to parties and arbitrators and
has amended the proposed language of
the parenthetical accordingly.22 FINRA
is also proposing in that same paragraph
to replace the phrase ‘‘be relevant in’’
with the phrase ‘‘apply to’’ because
‘‘apply to’’ would more precisely convey
the intended meaning of the sentence.23
In addition, commenters asked for new
language indicating that items on the
Customer List may not apply in a
particular case depending on the claims
asserted.24 FINRA agrees that adding
such guidance regarding customer
claims would be helpful, and has
amended the proposed rule change
accordingly.25
In the initial proposed rule change,
FINRA included language stating that
electronic files are ‘‘documents’’ within
the meaning of the Discovery Guide.26
Commenters suggested that FINRA
should include additional guidance
concerning electronic files.27 FINRA
responded that it understands that
issues relating to electronic discovery
are becoming more prevalent and
intends to recommend that the
Discovery Task Force include the topic
on its agenda.28 However, FINRA is not
proposing any additional revisions
concerning electronic discovery at this
time.
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19157
discovery rules, including through
reluctance to impose sanctions for party
failure to comply with discovery
rules.32 FINRA believes that the
appropriate places to address the
arbitrators’ duty to enforce discovery
requirements are the Code of Arbitration
Procedure and FINRA’s training
materials.33 FINRA stated that it trains
arbitrators concerning the discovery
rules and available sanctions.34 FINRA
also stated that, to reinforce the training,
it had included a discussion in the
revised Arbitrator’s Reference Guide
(which FINRA indicated would be
posted to FINRA’s Web site in the near
future) that addresses discovery
obligations and discusses sanctions.35
B. Document Production Lists
1. Eliminating the Discovery Guide
Several commenters asserted that
FINRA should eliminate the Discovery
Guide.36 FINRA disagreed with the
commenters and stated that experience
with the current Discovery Guide since
its inauguration in 1999 indicates that
the Discovery Guide and its Lists help
parties obtain the documents they need
to develop a case.37 FINRA believes that
the proposed rule change, which
incorporated user feedback after years of
experience with the Discovery Guide,
will improve the discovery process for
customers, and for firms and their
associated persons.38
2. Production Burden
Several commenters expressed the
view that document production under
the Guide is burdensome to investors.39
Others raised concerns about the
burdens imposed on firms and their
associated persons.40 FINRA stated that
it created the Discovery Guide to
facilitate the exchange of the kinds of
documents that parties routinely sought
during discovery and that arbitrators
regularly ordered produced. FINRA also
stated that the proposed revisions reflect
experience gained over the years since
FINRA implemented the Discovery
Guide.41 In addition, FINRA stated that
32 See Krebsbach, Lewins, PIABA, and Boliver
comments.
33 Response Letter.
34 Id.
35 Id.
36 See Lipner, McCauley, Gard, Terry, Evans and
Edmiston, and Bleecher comments.
37 Response Letter.
38 Id.
39 See Lipner, McCauley, Neuman, Krebsbach,
James, Evans and Edmiston, Doss, Ruby, Smiley,
Estell, Mougey, Bleecher, NASAA, Davis, Layne,
and Ilgenfritz comments.
40 See Cox, Krebsbach, Janney, Evangelista, Ulmer
& Berne, SIFMA, and Drinker Biddle comments.
41 Response Letter.
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balancing the desire to provide parties
with the documents they need to
prepare their cases with a desire to
minimize production burdens is
challenging, but, based on years of
experience with the Discovery Guide
and constituent feedback, FINRA
believed that the proposed rule change,
as amended, would strike an
appropriate balance.42
3. Two List Format
Several commenters objected to
FINRA’s proposal to consolidate the
Lists from 14 claim-specific lists to two
general Lists (one for firms and their
associated persons, and one for
customers) citing, among other
objections, additional production
burdens and the potential for producing
documents that are not needed in every
case.43 FINRA stated that it proposed
the consolidation in response to
suggestions from advocates for
customers that FINRA eliminate the
Lists for specific types of claims because
customers are not required to plead
causes of action under the Customer
Code.44 FINRA also stated that, along
with consolidating the Lists, FINRA
proposed expanding the guidance it
gives to arbitrators in the Discovery
Guide’s introduction on how to handle
discovery issues so that arbitrators
understand that they may tailor the
Discovery Guide to unique
circumstances that arise in arbitration
cases.45 FINRA stated that the
consolidation would better serve forum
users and ultimately reduce the number
and limit the scope of disputes
involving document production.46
4. Time Periods and Scope of
Production
Several commenters objected to the
time periods specified in the proposed
consolidated List items.47 FINRA
responded by stating that investor and
industry representatives that
mstockstill on DSKH9S0YB1PROD with NOTICES
42 Id.
43 See Port, Cox, Shaw, Krebsbach, Brodherson,
Janney, Yorsz, Shaffner, Martens, Ulmer & Berne,
and SIFMA comments.
44 FINRA stated that it proposed to update the
Discovery Guide in 2008, and, although the 2008
proposal was withdrawn, FINRA incorporated
many suggestions made in comments on that
proposal, including the suggestion that FINRA
consolidate the lists, in the current proposal. See
Response Letter.
45 Response Letter.
46 Id.
47 See Stephens, Caruso, Krosschell, Pounds,
Evans and Edmiston, Smiley, Ulmer & Berne, Estell,
Raymond James, Shillinger, Shafner, Mougey,
PIABA, Cornell Securities Law Clinic, Davis,
Goldstein, Layne, SIFMA, Boliver, and Drinker
Biddle comments. Commenters asserted, among
other objections, that time periods were too short,
or too long, or were not consistent between
customers and firms/associated persons.
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16:52 Apr 05, 2011
Jkt 223001
collaborated with FINRA on the
proposed rule change considered each
List item on its own merits and
discussed, over several meetings, the
time periods for each item.48 FINRA
explained that, given the effort that
went into determining appropriate time
periods for production, FINRA was not
proposing to change any of the time
periods in the proposed rule change.49
FINRA also stated that the Discovery
Task Force may choose to revisit the
time periods for production of certain
documents after forum users have
gained experience with the revised
Discovery Guide.50
5. Product Cases
Several commenters raised concerns
that the Guide does not sufficiently
address claims alleging the defective
structuring or widespread mismarketing
of a specific security, or ‘‘product
cases.’’ 51 One commenter expressed the
belief that the Guide should not address
specific products.52 FINRA responded
by stating that it believes product cases
are an appropriate subject for the
Discovery Task Force, and that it
intends to suggest that the Task Force
consider the topic further.53
6. Distinguishing Customer Parties From
Other Customers
Commenters asked FINRA to revise
the proposed List items to distinguish
between customers that are parties to a
case and other, non-party customers.54
FINRA agreed that making such a
distinction in the proposed List items
would add clarity to the Discovery
Guide.55 FINRA has accordingly
amended the proposed preamble to the
Lists to state that, throughout the Lists,
FINRA will refer to customers that are
parties to an arbitration case as
‘‘customer parties’’ and other, non-party
customers as ‘‘customers.’’ 56
7. Accounts or Transactions at Issue
Several proposed List items called for
a firm or associated person to produce
documents relating to the accounts or
transactions at issue.57 Upon further
consideration, FINRA has amended the
proposed rule change by specifying that,
in addition to documents relating to the
accounts or transactions at issue, these
48 Response
Letter.
49 Id.
50 Id.
51 See Lipner, Bakhtiari, Malecki, Mougey, and
Goldstein comments.
52 See Krebsbach comments.
53 Response Letter.
54 See SIFMA and Raymond James comments.
55 Response Letter.
56 Id.
57 See List 1, items 2, 7, 9, 11, 12, 13, and 17.
PO 00000
Frm 00130
Fmt 4703
Sfmt 4703
items cover documents relating to the
claims, and products or types of
products, at issue.58
C. Individual List Items
In addition to the amendments
described above, FINRA has made a
number of revisions to the proposed
rule change that are specific to
individual items on the Lists.
1. List 1, Item 2
As initially proposed, this item would
have called for production of all
correspondence sent to customers or
received by firms and their associated
persons specifically relating to the
accounts or transactions at issue
including, but not limited to, documents
relating to asset allocation,
diversification, trading strategies, and
market conditions; and all advertising
materials sent to customers of the firm
that refer to the securities or account
types at issue.59 Unless separately
requested, the documents would not
have included confirmation slips and
monthly statements.
FINRA has made several changes to
this proposed item that FINRA believes
would clarify the item’s application and
provide additional guidance to parties
and arbitrators.60 As amended, the item
would require production of all
correspondence sent to the customer
parties or received by the firm or its
associated persons that relate to the
claims, accounts, transactions, or
products or types of products at issue
including, but not limited to, documents
relating to asset allocation,
diversification, trading strategies, and
market conditions; and all advertising
materials sent to customers of the firm
that refer to the products or account
types that are at issue or that were used
by the firm or its associated persons to
solicit or provide services to the
customer parties. In addition, if
requested, the documents would
include confirmation slips and monthly
statements. Even if not requested, the
documents would include confirmation
slips and monthly statements that have
handwritten notations or that are not
identical to those the firm sent to the
customer parties.
2. List 1, Item 4
Currently, for claims alleging
unauthorized trading, the Discovery
Guide presumes that firms will produce
order tickets for the customers’
transactions at issue. FINRA initially
proposed to delete this requirement on
58 Response
Letter.
note 3 supra.
60 Response Letter.
59 See
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the grounds that production of order
tickets is burdensome, and evidence
relating to whether the claimants
authorized a particular transaction
would be produced under proposed List
1, Items 4, 6, and 8. Several commenters
objected to the proposed deletion and
stated, among other things, that order
tickets provide evidence of whether a
trade was solicited or unsolicited,
evidence of whether a trade was
reviewed and approved by supervisory
personnel, and evidence of the time that
an order was entered.61 FINRA found
the comments persuasive, and has
amended the proposed item to restore
the presumption that firms will produce
order tickets for the customer parties’
transactions at issue in cases alleging
unauthorized trading.62 FINRA believes
that the arbitrators can effectively
address issues of production burden on
a case-by-case basis.63
3. List 1, Item 5(a)
As initially proposed, this item would
have provided for production of all
materials that the firm or its associated
persons prepared, used or provided to
customers relating to the transactions or
products at issue, including research
reports, sales materials, performance or
risk data, prospectuses, and other
offering documents, including
documents intended or identified as
being ‘‘for internal use only.’’ 64 In
response to comments, FINRA is
proposing to amend the proposed item
to clarify its intended scope by
specifying that the documents include
copies of news articles or outside
research.65
4. List 1, Item 6
mstockstill on DSKH9S0YB1PROD with NOTICES
As initially proposed, this item would
have required production of all notes
the firm or its associated persons made,
including, but not limited to, entries in
any diary or calendar, relating to the
customers or the customers’ accounts or
transactions at issue.66 For clarity,
FINRA has amended this proposed item
to require production of all notes the
firm or its associated persons made
relating to the customer parties or the
customer parties’ claims, accounts,
transactions, or products or types of
products at issue, including, but not
limited to, entries in any diary or
calendar, relating to the claims or
products at issue.67
5. List 1, Item 7(a)
As initially proposed, this item would
have required production of all notes or
memoranda evidencing supervisory,
compliance, or managerial review of the
customers’ accounts or trades therein for
the period at issue.68 FINRA has
amended this proposed item to expand
the guidance provided to parties and
arbitrators by requiring production of all
notes or memoranda evidencing
supervisory, compliance, or managerial
review of the customer parties’ accounts
or transactions therein or of the
associated persons assigned to the
customer parties’ accounts for the
period at issue.69
income tax returns must be identical to
those that were filed with the Internal
Revenue Service.75 To add clarity to the
proposed item, FINRA has amended it
by moving the sentence indicating that
tax returns must be identical so that it
appears immediately above the
statement permitting redaction of the
returns.76
9. List 2, Item 4
This item concerns the customers’
accounts at firms that are not parties to
the matter. For clarity, FINRA has
amended the proposed item by
distinguishing between non-party firms
and party firms.77
10. List 2, Item 8
This item relates to telephone records.
In the initial proposed rule change,
6. List 1, Item 14
FINRA stated that it was not proposing
As initially proposed, this item would any substantive changes to the
have required production of portions of
Discovery Guide’s application to
internal audit reports for the branch in
telephone records.78 In response to
which the customers maintained
comments regarding that statement,
accounts that ‘‘focused on’’ associated
FINRA offered a clarification.79 FINRA
persons or the accounts or transactions
states that, under the current Discovery
at issue.70 FINRA has amended this item Guide, customers are required to
to clarify its intended scope by
produce certain documents relating to
replacing ‘‘focused on’’ with
telephone records only if they are
‘‘concern.’’ 71
alleging unauthorized trading.80 In
contrast, proposed item 8 would require
7. List 1, Item 15
customers to produce the specified
As initially proposed, this item would documents in every case, which is more
have required production of records of
than a ministerial change.81
disciplinary action taken against a firm’s
11. List 2, Item 17
associated persons by any regulator or
employer for all sales practice violations
As initially proposed, this item would
or conduct similar to the conduct
have required production of documents
72
alleged in the Statement of Claim.
showing the customers’ complete
FINRA has amended this proposed item educational and employment
to clarify its intended scope by
background or, in the alternative, a
including the same parenthetical
description of the customers’
reference to ‘‘state, federal or selfeducational and employment
regulatory organization’’ that FINRA
background if not set forth in resumes
uses in other items in the Discovery
produced under item 16.82 FINRA has
Guide that refer to regulators.73
amended this proposed item by revising
8. List 2, Item 1
As initially proposed, this item
(relating to customer tax documents)
would have stated that customers may
redact information relating to medical
and dental expenses and the names of
charities on Schedule A of their tax
return unless the information is related
to the allegations in the Statement of
Claim.74 The proposed statement was
followed by language indicating that
it to require production of any existing
description of the customer parties’
educational and employment
background if not set forth in resumes
produced under item 16.
12. List 2, Item 19
This item concerns insurance
products that provide a death benefit.
As initially proposed, it would have
75 Id.
76 Response
61 See
Stephens, Caruso, Nygaard, Krosschell,
Evans and Edmiston, Schillinger, Layne, and
Pounds comments.
62 Response Letter.
63 Id.
64 See note 3 supra.
65 See Response Letter. Cf. Estell comments
(relating to news articles or outside research).
66 See note 3 supra.
VerDate Mar<15>2010
16:52 Apr 05, 2011
Jkt 223001
19159
67 Response
Letter.
68 See note 3 supra.
69 Response Letter.
70 See note 3 supra.
71 Response Letter. Cf. Estell comments (relating
to the term ‘‘focused on’’).
72 See note 3 supra.
73 Response Letter.
74 See note 3 supra.
PO 00000
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Fmt 4703
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Letter.
77 Id.
78 See
note 3 supra.
Letter. In its comment, PIABA
questioned whether there was an error in the rule
text of List 2, Item 8(b) because it did not limit
production to claims alleging unauthorized trading.
80 Response Letter.
81 Id.
82 See note 3 supra.
79 Response
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required customers to produce all
insurance information received from an
insurance sales agent or securities
broker relating to such insurance.83
FINRA has amended the proposed item
to clarify its intended scope by deleting
the reference to ‘‘insurance’’ before
‘‘information.’’ 84
III. Commission’s Findings
After careful review of the proposed
rule change, the comment letters and
the FINRA Response Letter, the
Commission finds that the proposed
rule change, as modified by Amendment
No. 1, is consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
a national securities association.85 In
particular, the Commission finds that
the proposed rule change is consistent
with Section 15A(b)(6) of the Act,86
which requires, among other things, that
FINRA rules be designed to prevent
fraudulent and manipulative acts and
practices, to promote just and equitable
principles of trade, and, in general, to
protect investors and the public interest.
The Commission believes that the
revisions to the Discovery Guide will
help reduce the number and limit the
scope of disputes involving document
production and other matters, thereby
improving the arbitration process for the
benefit of the public investors, brokerdealer firms, and associated persons
who use the process. The revisions to
the Discovery Guide are the result of
over six years of consultation by FINRA
with its constituents. The Commission
also expects that further improvement of
the process should be possible through
the Discovery Task Force’s
consideration of discovery issues as
they arise.87
IV. Accelerated Approval
The Commission finds goods cause,
pursuant to Section 19(b)(2) of the
Exchange Act,88 for approving the
proposed rule change, as modified by
Amendment No. 1 thereto, prior to the
30th day after publication of notice of
the filing of Amendment No. 1 in the
Federal Register. The proposed rule
change was informed by FINRA’s
consideration of, and the incorporation
of many suggestions made in, extensive
mstockstill on DSKH9S0YB1PROD with NOTICES
83 See
note 3 supra.
Letter.
85 In approving this proposal, the Commission has
considered the proposed rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
86 15 U.S.C. 78o–3(b)(6).
87 Cf. Response Letter (describing plans for further
consideration of issues by the Discovery Task
Force).
88 15 U.S.C. 78s(b)(2).
84 Response
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16:52 Apr 05, 2011
Jkt 223001
comments on a 2008 proposal to update
the Discovery Guide, and Amendment
No. 1’s modifications to the proposed
rule change add clarity to the Discovery
Guide and provide additional guidance
to parties and arbitrators.
Accordingly, the Commission finds
that good cause exists to approve the
proposal, as modified by Amendment
No. 1, on an accelerated basis.
V. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change, as modified by Amendment No.
1, is consistent with the Act. Comments
may be submitted by any of the
following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–FINRA–2010–035 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–FINRA–2010–035. This file
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal office of
FINRA. All comments received will be
posted without change; the Commission
does not edit personal identifying
information from submissions. You
PO 00000
Frm 00132
Fmt 4703
Sfmt 4703
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–FINRA–2010–035 and
should be submitted on or before April
27, 2011.
VI. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,89 that the
proposed rule change (SR–FINRA–
2010–035), as modified by Amendment
No. 1, be, and hereby is, approved on an
accelerated basis.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.90
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–8200 Filed 4–5–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–64163; File No. SR–
NYSEAmex–2011–22]
Self-Regulatory Organizations; Notice
of Filing and Immediate Effectiveness
of Proposed Rule Change by NYSE
Amex LLC To Expand the $2.50 Strike
Price Program
March 31, 2011.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that, on March
29, 2011, NYSE Amex LLC (‘‘NYSE
Amex’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
Commentary .07 to NYSE Amex Rule
903 to expand the $2.50 Strike Price
Program. The text of the proposed rule
change is available at the principal
office of Exchange, the Commission’s
Public Reference Room, on the
Commission’s Web site at https://
www.sec.gov, and https://www.nyse.com.
89 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
90 17
E:\FR\FM\06APN1.SGM
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Agencies
[Federal Register Volume 76, Number 66 (Wednesday, April 6, 2011)]
[Notices]
[Pages 19155-19160]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-8200]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-64166; File No. SR-FINRA-2010-035]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of Amendment No. 1 and Order Granting
Accelerated Approval of a Proposed Rule Change, as Modified by
Amendment No. 1, Relating to Amendments to the Discovery Guide and
Rules 12506 and 12508 of the Code of Arbitration Procedure for Customer
Disputes
April 1, 2011.
I. Introduction
On July 12, 2010, the Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission (``SEC''
or ``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Exchange Act'' or ``Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to amend the Discovery Guide,
which includes Document Production Lists, and to make conforming
changes to Rules 12506 and 12508 of the Code of Arbitration Procedure
for Customer Disputes (``Customer Code''). The proposed rule change was
published for comment in the Federal Register on August 3, 2010.\3\ The
Commission received 55 comment letters on the
[[Page 19156]]
proposed rule change.\4\ On February 8, 2011, the Commission received
from FINRA a Response to Comments and Partial Amendment No. 1 to the
proposed rule change.\5\ The Commission is publishing this notice and
order to solicit comment on Amendment No. 1 and to approve the proposed
rule change, as modified by Amendment No. 1, on an accelerated basis.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Exchange Act Release No. 62584 (July 28, 2010), 75 FR
45685 (August 3, 2010).
\4\ See comment letters submitted by Richard A. Stephens, Esq.,
dated August 6, 2010 (``Stephens comment''); Seth E. Lipner, Esq.,
Baruch College, Member, Deutsch & Lipner, dated August 15, 2010
(``Lipner comment''); Leonard Steiner, Esq., dated August 16, 2010
(``Steiner comment''); Robert C. Port, Esq., Cohen Goldstein Port
Gottlieb, LLP, dated August 19, 2010 (``Port comment''); Steven M.
McCauley, Esq., dated August 19, 2010 (``McCauley comment''); Steven
B. Caruso, Esq., Maddox Hargett & Caruso, P.C., dated August 20,
2010 (``Caruso comment''); Diane Nygaard, Esq., dated August 20,
2010 (``Nygaard comment''); Ryan K. Bakhtiari, Esq., Aidikoff, Uhl
and Bakhtiari, dated August 20, 2010 (``Bakhtiari comment''); Thomas
R. Cox, Esq., Miller, Canfield, Paddock and Stone, P.L.C., dated
August 20, 2010 (``Cox comment''); Steven J. Gard, Esq., dated
August 22, 2010 (``Gard comment''); John W. Shaw, Esq., Berkowitz,
Oliver, Williams, Shaw and Eisenbrandt, dated August 23, 2010
(``Shaw comment''); Stephen Krosschell, Esq., Goodman & Nekvasil,
P.A., dated August 23, 2010 (``Krosschell comment''); David P.
Neuman, Esq., Stoltmann Law Offices, P.C., dated August 23, 2010
(``Neuman comment''); Theodore A. Krebsbach, Esq., Krebsbach and
Snyder, P.C., dated August 23, 2010 (``Krebsbach comment''); Eric G.
Wallis, Esq., Reed Smith LLP, dated August 23, 2010 (``Wallis
comment''); Herb Pounds, Jr., Esq., dated August 23, 2010 (``Pounds
comment''); Alan S. Brodherson, Esq., dated August 24, 2010
(``Brodherson comment''); Joseph Terry, dated August 24, 2010
(``Terry comment''); Mark James, dated August 24, 2010 (``James
comment''); Jonathan W. Evans, Esq., and Michael S. Edmiston, Esq.,
Law Offices of Jonathan W. Evans & Associates, dated August 24, 2010
(``Evans and Edmiston comment''); G. Kirk Ellis, Esq., dated August
24, 2010 (``Ellis comment''); Jason R. Doss, Esq., The Doss Firm,
LLC, dated August 24, 2010 (``Doss comment''); Jenice L. Malecki,
Esq., Malecki Law, dated August 24, 2010 (``Malecki comment'');
Frances Ruby, dated August 24, 2010 (``Ruby comment''); Carrie L.
Chelko, Esq., Deputy General Counsel, Janney Montgomery Scott LLC,
dated August 24, 2010 (``Janney comment''); Raymond W. Henney, Esq.,
Honigman Miller Schwartz and Cohn LLP, dated August 24, 2010
(``Henney comment''); Jonathan Kord Lagemann, Esq., dated August 24,
2010 (``Lagemann comment''); Brian N. Smiley, Esq., Smiley Bishop &
Porter, LLP, dated August 24, 2010 (``Smiley comment''); Stanley
Yorsz, Esq., Buchanan Ingersoll & Rooney PC, dated August 24, 2010
(``Yorsz comment''); Dominick F. Evangelista, Esq., Bressler, Amery
& Ross, P.C., dated August 24, 2010 (``Evangelista comment'');
Michael N. Ungar, Esq., Kenneth A. Bravo, Esq., Joseph S. Simms,
Esq., and Jill Y. Coen, Esq., Ulmer & Berne LLP, dated August 24,
2010 (``Ulmer & Berne comment''); Barry D. Estell, Esq., dated
August 24, 2010 (``Estell comment''); Richard A. Lewins, Esq., dated
August 24, 2010 (``Lewins comment''); Robert M. Rudnicki, Esq., Vice
President and Director of Litigation, Raymond James & Associates,
Inc., on behalf of Raymond James Financial, Inc. and Raymond James &
Associates, Inc., dated August 24, 2010 (``Raymond James comment'');
Lee H. Schillinger, dated August 24, 2010 (``Schillinger comment'');
Paula D. Shaffner, Esq., Stradley Ronon Stevens & Young, LLP, dated
August 24, 2010 (``Shaffner comment''); Kelly J. Moynihan, Esq.,
Keesal, Young & Logan, dated August 24, 2010 (``Moynihan comment'');
Richard L. Martens, Esq., Jason S. Haselkorn, Esq., Patricia M.
Christiansen, Esq., Charles L. Pickett, Esq., Casey Ciklin Lubitz
Martens & O'Connell, dated August 24, 2010 (``Casey Ciklin
comment''); Peter J. Mougey, Esq., Levin Papantonio Thomas Mitchell
Rafferty & Proctor, P.A., dated August 24, 2010 (``Mougey
comment''); Rob Bleecher, Esq., dated August 24, 2010 (``Bleecher
comment''); Scott R. Shewan, Esq., President, Public Investors
Arbitration Bar Association, dated August 24, 2010 (``PIABA
comment''); Bradford D. Kaufman, Esq., Greenberg Traurig, P.A.,
dated August 24, 2010 (``Kaufman comment''); William A. Jacobson,
Esq., Associate Clinical Professor, Cornell Law School, and
Director, Cornell Securities Law Clinic, dated August 24, 2010
(``Cornell Securities Law Clinic comment''); S. Lawrence Polk, Esq.,
Sutherland Asbill & Brennan LLP, dated August 24, 2010 (``Polk
comment''); John R. Cronin, Vermont Securities Director and Chair,
NASAA Arbitration Project Group, dated August 25, 2010 (``NASAA
comment''); Theodore M. Davis, Esq., dated August 25, 2010 (``Davis
comment''); Eliot Goldstein, Esq., Law Offices of Eliot Goldstein,
LLP, dated August 25, 2010 (``Goldstein comment''); Richard M.
Layne, Esq., dated August 26, 2010 (``Layne comment''); Royal B.
Lea, Esq., dated August 27, 2010 (``Lea comment''); Keith L.
Griffin, Esq., Griffin Law Firm, LLC, dated August 27, 2010
(``Griffin comment''); Patricia Cowart, Esq., Chair, SIFMA
Arbitration Committee, dated September 10, 2010 (``SIFMA comment'');
Gail E. Boliver, Esq., Boliver & Bidwell, dated September 16, 2010
(``Boliver comment''); Scott C. Ilgenfritz, Esq., Johnson, Pope,
Bokor, Ruppel & Burns, LLP, dated September 24, 2010 (``Ilgenfritz
comment''); Matthew Farley, Esq., Drinker Biddle & Reath LLP, dated
September 24, 2010 (``Drinker Biddle comment''); and Kathy A.
Besmer, dated November 6, 2010 (``Besmer comment'').
\5\ See letter from Margo A. Hassan, Assistant Chief Counsel,
FINRA Dispute Resolution, to Elizabeth Murphy, Secretary,
Commission, dated February 8, 2011 (``Response Letter''). The text
of the proposed rule change and FINRA's Response Letter are
available on FINRA's Web site at https://www.finra.org, at the
principal office of FINRA, on the Commission's Web site at https://www.sec.gov, and at the Commission's Public Reference Room.
---------------------------------------------------------------------------
II. Description of Proposed Rule Change and Summary of Comments
As described in Exchange Act Release No. 62584,\6\ FINRA is
proposing to amend the Discovery Guide, which includes Document
Production Lists, and to make conforming changes to Rules 12506 and
12508 of the Customer Code. Of the 55 comments received on the initial
proposal, 15 supported it with modifications,\7\ 36 opposed it,\8\ and
4 addressed particular aspects of the proposal without expressing a
position on whether the Commission should approve the proposed rule
change.\9\
---------------------------------------------------------------------------
\6\ See note 3 supra.
\7\ See Caruso, Bakhtiari, Cox, Pounds, Doss, Malecki, Smiley,
Lewins, Raymond James, Mougey, PIABA, Cornell Securities Law Clinic,
SIFMA, Boliver, and Ilgenfritz comments.
\8\ See Lipner, Steiner, Port, McCauley, Nygaard, Gard, Shaw,
Neuman, Krebsbach, Krosschell, Brodherson, Terry, James, Evans and
Edmiston, Ellis, Ruby, Janney, Lagemann, Yorsz, Evangelista, Ulmer &
Berne, Estell, Schillinger, Shaffner, Moynihan, Casey Ciklin,
Bleecher, Kaufman, NASAA, Davis, Goldstein, Layne, Lea, Griffin,
Drinker Biddle, and Besmer comments.
\9\ See Stephens, Wallis, Henney, and Polk comments.
---------------------------------------------------------------------------
In its Response Letter, FINRA stated that the initial proposed rule
change reflected several years of close consultation with FINRA's
constituents, including investor and industry representatives,
arbitrators, and attorneys that handle investor claims at securities
arbitration clinics. FINRA also stated that, because the Discovery
Guide, as amended by the initial proposed rule change, was comprised of
language that was discussed at length with these constituents and
crafted to balance the parties' discovery needs with the goal of
keeping FINRA arbitration efficient and cost effective, FINRA was, for
the most part, making only limited further revisions to the proposed
rule change to provide additional clarification and guidance.\10\
---------------------------------------------------------------------------
\10\ Response Letter.
---------------------------------------------------------------------------
In addition, FINRA stated that, if the Commission approves the
proposed rule change as amended, it would establish a Discovery Task
Force under the auspices of FINRA's National Arbitration and Mediation
Committee to review substantive issues relating to the Discovery Guide
on an ongoing basis, for the purpose of keeping the Discovery Guide
current as products change and new discovery issues arise.\11\ FINRA
stated that it would convene the Discovery Task Force approximately six
months after implementing the revised Discovery Guide to allow
practitioners time to gauge the efficacy of the new Discovery
Guide.\12\
---------------------------------------------------------------------------
\11\ Id.
\12\ Id.
---------------------------------------------------------------------------
FINRA's responses to comments and changes to the proposed rule
change made by Amendment No. 1 are described below.
A. Guide Introduction
1. Arbitrator Discretion
Commenters expressed concerns that arbitrators may adhere strictly
to the Discovery Guide's two lists of documents (the first itemizing
categories of documents to be produced by firms and their associated
persons, and the second itemizing categories of documents to be
produced by customers--together, ``Lists'') when making discovery
decisions and may not use the flexibility the Discovery Guide provides
to them.\13\ FINRA responded that it wants arbitrators to be aware of
the flexibility they have when
[[Page 19157]]
asked to decide discovery disputes, and therefore the initial proposal
included revisions to the introduction of the Discovery Guide stating
that arbitrators may order production of documents not appearing on the
Lists, and that arbitrators can order that parties do not have to
produce all items on the Lists in a particular case.\14\ Further, these
revisions added guidance on how arbitrators should handle objections
based on cost or burden of production.\15\
---------------------------------------------------------------------------
\13\ See Lipner, Krebsbach, Evans and Edmiston, Shaffner,
Bleecher, Griffin, Henney, NASAA, Yorsz, Goldstein, SIFMA, and
Drinker Biddle comments.
\14\ Response Letter.
\15\ Id.
---------------------------------------------------------------------------
In addition to these changes, and in response to commenters'
concerns, FINRA has proposed changes to the introduction to explain
that arbitrators must use their judgment in considering requests for
documents beyond those contained in the Lists and may not deny document
requests on the grounds that the documents are not expressly listed in
the Discovery Guide.\16\ FINRA stated that, in addition to expanding
the language in the Discovery Guide, if the SEC approves the proposed
rule change, FINRA would revise the Arbitrator's Reference Guide, which
is posted on the FINRA Web site, to include a discussion on how
arbitrators should use the new Discovery Guide.\17\ FINRA also stated
that it would update its arbitrator training materials to ensure that
FINRA makes arbitrators aware of the revisions.\18\ In addition, FINRA
stated that it would offer training on the revised Discovery Guide in a
workshop that FINRA would post as an audio file on its Web site if the
proposed rule change, as amended, is approved.\19\
---------------------------------------------------------------------------
\16\ Id.
\17\ Id.
\18\ Id.
\19\ Id.
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2. Business Models and Types of Customer Claims
FINRA initially proposed adding language to the introduction of the
Discovery Guide stating that parties and arbitrators should recognize
that not all firms have the same business models and that certain items
on the Lists may not be relevant in a particular case when the firm's
business model (e.g., full service firm, discount broker, or online
broker) is taken into consideration.\20\ Commenters requested that
FINRA add ``clearing firm'' to the parenthetical listing examples of
business models.\21\ FINRA agrees that adding ``clearing firm'' to the
parenthetical would be helpful to parties and arbitrators and has
amended the proposed language of the parenthetical accordingly.\22\
FINRA is also proposing in that same paragraph to replace the phrase
``be relevant in'' with the phrase ``apply to'' because ``apply to''
would more precisely convey the intended meaning of the sentence.\23\
In addition, commenters asked for new language indicating that items on
the Customer List may not apply in a particular case depending on the
claims asserted.\24\ FINRA agrees that adding such guidance regarding
customer claims would be helpful, and has amended the proposed rule
change accordingly.\25\
---------------------------------------------------------------------------
\20\ See note 3 supra.
\21\ See SIFMA and Drinker Biddle comments. The Drinker Biddle
comment also asked FINRA to add ``prime-brokerage firm'' to the
parenthetical. FINRA believes that adding ``clearing firm'' to the
parenthetical will add sufficient clarity for the Guide's users and
is not proposing to add ``prime-brokerage firm'' at this time.
\22\ Response Letter.
\23\ Id.
\24\ See PIABA and Caruso comments.
\25\ Response Letter.
---------------------------------------------------------------------------
In the initial proposed rule change, FINRA included language
stating that electronic files are ``documents'' within the meaning of
the Discovery Guide.\26\ Commenters suggested that FINRA should include
additional guidance concerning electronic files.\27\ FINRA responded
that it understands that issues relating to electronic discovery are
becoming more prevalent and intends to recommend that the Discovery
Task Force include the topic on its agenda.\28\ However, FINRA is not
proposing any additional revisions concerning electronic discovery at
this time.
---------------------------------------------------------------------------
\26\ See note 3 supra.
\27\ See Yorsz and Martens comments.
\28\ Response Letter.
---------------------------------------------------------------------------
3. Privilege
Several commenters raised concerns that List items might require
production of privileged documents.\29\ One commenter suggested that
parties raise objections based on unspecified or unrecognized
privileges.\30\ Based on these comments, FINRA believes that additional
guidance on acceptable grounds for assertions of privilege would be
helpful to parties and arbitrators, and is proposing to add language to
the introduction stating that parties are not required to produce
documents that are otherwise subject to an established privilege,
including the attorney-client privilege and attorney work product
doctrine.\31\
---------------------------------------------------------------------------
\29\ See Krosschell, Pounds, Evans and Edmiston, Schillinger,
PIABA, Polk, Layne, SIFMA, Drinker Biddle, and Janney comments.
\30\ See Estell comments.
\31\ Id.
---------------------------------------------------------------------------
4. Enforcing Document Production
Commenters raised concerns about arbitrators not adequately
enforcing the discovery rules, including through reluctance to impose
sanctions for party failure to comply with discovery rules.\32\ FINRA
believes that the appropriate places to address the arbitrators' duty
to enforce discovery requirements are the Code of Arbitration Procedure
and FINRA's training materials.\33\ FINRA stated that it trains
arbitrators concerning the discovery rules and available sanctions.\34\
FINRA also stated that, to reinforce the training, it had included a
discussion in the revised Arbitrator's Reference Guide (which FINRA
indicated would be posted to FINRA's Web site in the near future) that
addresses discovery obligations and discusses sanctions.\35\
---------------------------------------------------------------------------
\32\ See Krebsbach, Lewins, PIABA, and Boliver comments.
\33\ Response Letter.
\34\ Id.
\35\ Id.
---------------------------------------------------------------------------
B. Document Production Lists
1. Eliminating the Discovery Guide
Several commenters asserted that FINRA should eliminate the
Discovery Guide.\36\ FINRA disagreed with the commenters and stated
that experience with the current Discovery Guide since its inauguration
in 1999 indicates that the Discovery Guide and its Lists help parties
obtain the documents they need to develop a case.\37\ FINRA believes
that the proposed rule change, which incorporated user feedback after
years of experience with the Discovery Guide, will improve the
discovery process for customers, and for firms and their associated
persons.\38\
---------------------------------------------------------------------------
\36\ See Lipner, McCauley, Gard, Terry, Evans and Edmiston, and
Bleecher comments.
\37\ Response Letter.
\38\ Id.
---------------------------------------------------------------------------
2. Production Burden
Several commenters expressed the view that document production
under the Guide is burdensome to investors.\39\ Others raised concerns
about the burdens imposed on firms and their associated persons.\40\
FINRA stated that it created the Discovery Guide to facilitate the
exchange of the kinds of documents that parties routinely sought during
discovery and that arbitrators regularly ordered produced. FINRA also
stated that the proposed revisions reflect experience gained over the
years since FINRA implemented the Discovery Guide.\41\ In addition,
FINRA stated that
[[Page 19158]]
balancing the desire to provide parties with the documents they need to
prepare their cases with a desire to minimize production burdens is
challenging, but, based on years of experience with the Discovery Guide
and constituent feedback, FINRA believed that the proposed rule change,
as amended, would strike an appropriate balance.\42\
---------------------------------------------------------------------------
\39\ See Lipner, McCauley, Neuman, Krebsbach, James, Evans and
Edmiston, Doss, Ruby, Smiley, Estell, Mougey, Bleecher, NASAA,
Davis, Layne, and Ilgenfritz comments.
\40\ See Cox, Krebsbach, Janney, Evangelista, Ulmer & Berne,
SIFMA, and Drinker Biddle comments.
\41\ Response Letter.
\42\ Id.
---------------------------------------------------------------------------
3. Two List Format
Several commenters objected to FINRA's proposal to consolidate the
Lists from 14 claim-specific lists to two general Lists (one for firms
and their associated persons, and one for customers) citing, among
other objections, additional production burdens and the potential for
producing documents that are not needed in every case.\43\ FINRA stated
that it proposed the consolidation in response to suggestions from
advocates for customers that FINRA eliminate the Lists for specific
types of claims because customers are not required to plead causes of
action under the Customer Code.\44\ FINRA also stated that, along with
consolidating the Lists, FINRA proposed expanding the guidance it gives
to arbitrators in the Discovery Guide's introduction on how to handle
discovery issues so that arbitrators understand that they may tailor
the Discovery Guide to unique circumstances that arise in arbitration
cases.\45\ FINRA stated that the consolidation would better serve forum
users and ultimately reduce the number and limit the scope of disputes
involving document production.\46\
---------------------------------------------------------------------------
\43\ See Port, Cox, Shaw, Krebsbach, Brodherson, Janney, Yorsz,
Shaffner, Martens, Ulmer & Berne, and SIFMA comments.
\44\ FINRA stated that it proposed to update the Discovery Guide
in 2008, and, although the 2008 proposal was withdrawn, FINRA
incorporated many suggestions made in comments on that proposal,
including the suggestion that FINRA consolidate the lists, in the
current proposal. See Response Letter.
\45\ Response Letter.
\46\ Id.
---------------------------------------------------------------------------
4. Time Periods and Scope of Production
Several commenters objected to the time periods specified in the
proposed consolidated List items.\47\ FINRA responded by stating that
investor and industry representatives that collaborated with FINRA on
the proposed rule change considered each List item on its own merits
and discussed, over several meetings, the time periods for each
item.\48\ FINRA explained that, given the effort that went into
determining appropriate time periods for production, FINRA was not
proposing to change any of the time periods in the proposed rule
change.\49\ FINRA also stated that the Discovery Task Force may choose
to revisit the time periods for production of certain documents after
forum users have gained experience with the revised Discovery
Guide.\50\
---------------------------------------------------------------------------
\47\ See Stephens, Caruso, Krosschell, Pounds, Evans and
Edmiston, Smiley, Ulmer & Berne, Estell, Raymond James, Shillinger,
Shafner, Mougey, PIABA, Cornell Securities Law Clinic, Davis,
Goldstein, Layne, SIFMA, Boliver, and Drinker Biddle comments.
Commenters asserted, among other objections, that time periods were
too short, or too long, or were not consistent between customers and
firms/associated persons.
\48\ Response Letter.
\49\ Id.
\50\ Id.
---------------------------------------------------------------------------
5. Product Cases
Several commenters raised concerns that the Guide does not
sufficiently address claims alleging the defective structuring or
widespread mismarketing of a specific security, or ``product cases.''
\51\ One commenter expressed the belief that the Guide should not
address specific products.\52\ FINRA responded by stating that it
believes product cases are an appropriate subject for the Discovery
Task Force, and that it intends to suggest that the Task Force consider
the topic further.\53\
---------------------------------------------------------------------------
\51\ See Lipner, Bakhtiari, Malecki, Mougey, and Goldstein
comments.
\52\ See Krebsbach comments.
\53\ Response Letter.
---------------------------------------------------------------------------
6. Distinguishing Customer Parties From Other Customers
Commenters asked FINRA to revise the proposed List items to
distinguish between customers that are parties to a case and other,
non-party customers.\54\ FINRA agreed that making such a distinction in
the proposed List items would add clarity to the Discovery Guide.\55\
FINRA has accordingly amended the proposed preamble to the Lists to
state that, throughout the Lists, FINRA will refer to customers that
are parties to an arbitration case as ``customer parties'' and other,
non-party customers as ``customers.'' \56\
---------------------------------------------------------------------------
\54\ See SIFMA and Raymond James comments.
\55\ Response Letter.
\56\ Id.
---------------------------------------------------------------------------
7. Accounts or Transactions at Issue
Several proposed List items called for a firm or associated person
to produce documents relating to the accounts or transactions at
issue.\57\ Upon further consideration, FINRA has amended the proposed
rule change by specifying that, in addition to documents relating to
the accounts or transactions at issue, these items cover documents
relating to the claims, and products or types of products, at
issue.\58\
---------------------------------------------------------------------------
\57\ See List 1, items 2, 7, 9, 11, 12, 13, and 17.
\58\ Response Letter.
---------------------------------------------------------------------------
C. Individual List Items
In addition to the amendments described above, FINRA has made a
number of revisions to the proposed rule change that are specific to
individual items on the Lists.
1. List 1, Item 2
As initially proposed, this item would have called for production
of all correspondence sent to customers or received by firms and their
associated persons specifically relating to the accounts or
transactions at issue including, but not limited to, documents relating
to asset allocation, diversification, trading strategies, and market
conditions; and all advertising materials sent to customers of the firm
that refer to the securities or account types at issue.\59\ Unless
separately requested, the documents would not have included
confirmation slips and monthly statements.
---------------------------------------------------------------------------
\59\ See note 3 supra.
---------------------------------------------------------------------------
FINRA has made several changes to this proposed item that FINRA
believes would clarify the item's application and provide additional
guidance to parties and arbitrators.\60\ As amended, the item would
require production of all correspondence sent to the customer parties
or received by the firm or its associated persons that relate to the
claims, accounts, transactions, or products or types of products at
issue including, but not limited to, documents relating to asset
allocation, diversification, trading strategies, and market conditions;
and all advertising materials sent to customers of the firm that refer
to the products or account types that are at issue or that were used by
the firm or its associated persons to solicit or provide services to
the customer parties. In addition, if requested, the documents would
include confirmation slips and monthly statements. Even if not
requested, the documents would include confirmation slips and monthly
statements that have handwritten notations or that are not identical to
those the firm sent to the customer parties.
---------------------------------------------------------------------------
\60\ Response Letter.
---------------------------------------------------------------------------
2. List 1, Item 4
Currently, for claims alleging unauthorized trading, the Discovery
Guide presumes that firms will produce order tickets for the customers'
transactions at issue. FINRA initially proposed to delete this
requirement on
[[Page 19159]]
the grounds that production of order tickets is burdensome, and
evidence relating to whether the claimants authorized a particular
transaction would be produced under proposed List 1, Items 4, 6, and 8.
Several commenters objected to the proposed deletion and stated, among
other things, that order tickets provide evidence of whether a trade
was solicited or unsolicited, evidence of whether a trade was reviewed
and approved by supervisory personnel, and evidence of the time that an
order was entered.\61\ FINRA found the comments persuasive, and has
amended the proposed item to restore the presumption that firms will
produce order tickets for the customer parties' transactions at issue
in cases alleging unauthorized trading.\62\ FINRA believes that the
arbitrators can effectively address issues of production burden on a
case-by-case basis.\63\
---------------------------------------------------------------------------
\61\ See Stephens, Caruso, Nygaard, Krosschell, Evans and
Edmiston, Schillinger, Layne, and Pounds comments.
\62\ Response Letter.
\63\ Id.
---------------------------------------------------------------------------
3. List 1, Item 5(a)
As initially proposed, this item would have provided for production
of all materials that the firm or its associated persons prepared, used
or provided to customers relating to the transactions or products at
issue, including research reports, sales materials, performance or risk
data, prospectuses, and other offering documents, including documents
intended or identified as being ``for internal use only.'' \64\ In
response to comments, FINRA is proposing to amend the proposed item to
clarify its intended scope by specifying that the documents include
copies of news articles or outside research.\65\
---------------------------------------------------------------------------
\64\ See note 3 supra.
\65\ See Response Letter. Cf. Estell comments (relating to news
articles or outside research).
---------------------------------------------------------------------------
4. List 1, Item 6
As initially proposed, this item would have required production of
all notes the firm or its associated persons made, including, but not
limited to, entries in any diary or calendar, relating to the customers
or the customers' accounts or transactions at issue.\66\ For clarity,
FINRA has amended this proposed item to require production of all notes
the firm or its associated persons made relating to the customer
parties or the customer parties' claims, accounts, transactions, or
products or types of products at issue, including, but not limited to,
entries in any diary or calendar, relating to the claims or products at
issue.\67\
---------------------------------------------------------------------------
\66\ See note 3 supra.
\67\ Response Letter.
---------------------------------------------------------------------------
5. List 1, Item 7(a)
As initially proposed, this item would have required production of
all notes or memoranda evidencing supervisory, compliance, or
managerial review of the customers' accounts or trades therein for the
period at issue.\68\ FINRA has amended this proposed item to expand the
guidance provided to parties and arbitrators by requiring production of
all notes or memoranda evidencing supervisory, compliance, or
managerial review of the customer parties' accounts or transactions
therein or of the associated persons assigned to the customer parties'
accounts for the period at issue.\69\
---------------------------------------------------------------------------
\68\ See note 3 supra.
\69\ Response Letter.
---------------------------------------------------------------------------
6. List 1, Item 14
As initially proposed, this item would have required production of
portions of internal audit reports for the branch in which the
customers maintained accounts that ``focused on'' associated persons or
the accounts or transactions at issue.\70\ FINRA has amended this item
to clarify its intended scope by replacing ``focused on'' with
``concern.'' \71\
---------------------------------------------------------------------------
\70\ See note 3 supra.
\71\ Response Letter. Cf. Estell comments (relating to the term
``focused on'').
---------------------------------------------------------------------------
7. List 1, Item 15
As initially proposed, this item would have required production of
records of disciplinary action taken against a firm's associated
persons by any regulator or employer for all sales practice violations
or conduct similar to the conduct alleged in the Statement of
Claim.\72\ FINRA has amended this proposed item to clarify its intended
scope by including the same parenthetical reference to ``state, federal
or self-regulatory organization'' that FINRA uses in other items in the
Discovery Guide that refer to regulators.\73\
---------------------------------------------------------------------------
\72\ See note 3 supra.
\73\ Response Letter.
---------------------------------------------------------------------------
8. List 2, Item 1
As initially proposed, this item (relating to customer tax
documents) would have stated that customers may redact information
relating to medical and dental expenses and the names of charities on
Schedule A of their tax return unless the information is related to the
allegations in the Statement of Claim.\74\ The proposed statement was
followed by language indicating that income tax returns must be
identical to those that were filed with the Internal Revenue
Service.\75\ To add clarity to the proposed item, FINRA has amended it
by moving the sentence indicating that tax returns must be identical so
that it appears immediately above the statement permitting redaction of
the returns.\76\
---------------------------------------------------------------------------
\74\ See note 3 supra.
\75\ Id.
\76\ Response Letter.
---------------------------------------------------------------------------
9. List 2, Item 4
This item concerns the customers' accounts at firms that are not
parties to the matter. For clarity, FINRA has amended the proposed item
by distinguishing between non-party firms and party firms.\77\
---------------------------------------------------------------------------
\77\ Id.
---------------------------------------------------------------------------
10. List 2, Item 8
This item relates to telephone records. In the initial proposed
rule change, FINRA stated that it was not proposing any substantive
changes to the Discovery Guide's application to telephone records.\78\
In response to comments regarding that statement, FINRA offered a
clarification.\79\ FINRA states that, under the current Discovery
Guide, customers are required to produce certain documents relating to
telephone records only if they are alleging unauthorized trading.\80\
In contrast, proposed item 8 would require customers to produce the
specified documents in every case, which is more than a ministerial
change.\81\
---------------------------------------------------------------------------
\78\ See note 3 supra.
\79\ Response Letter. In its comment, PIABA questioned whether
there was an error in the rule text of List 2, Item 8(b) because it
did not limit production to claims alleging unauthorized trading.
\80\ Response Letter.
\81\ Id.
---------------------------------------------------------------------------
11. List 2, Item 17
As initially proposed, this item would have required production of
documents showing the customers' complete educational and employment
background or, in the alternative, a description of the customers'
educational and employment background if not set forth in resumes
produced under item 16.\82\ FINRA has amended this proposed item by
revising it to require production of any existing description of the
customer parties' educational and employment background if not set
forth in resumes produced under item 16.
---------------------------------------------------------------------------
\82\ See note 3 supra.
---------------------------------------------------------------------------
12. List 2, Item 19
This item concerns insurance products that provide a death benefit.
As initially proposed, it would have
[[Page 19160]]
required customers to produce all insurance information received from
an insurance sales agent or securities broker relating to such
insurance.\83\ FINRA has amended the proposed item to clarify its
intended scope by deleting the reference to ``insurance'' before
``information.'' \84\
---------------------------------------------------------------------------
\83\ See note 3 supra.
\84\ Response Letter.
---------------------------------------------------------------------------
III. Commission's Findings
After careful review of the proposed rule change, the comment
letters and the FINRA Response Letter, the Commission finds that the
proposed rule change, as modified by Amendment No. 1, is consistent
with the requirements of the Act and the rules and regulations
thereunder applicable to a national securities association.\85\ In
particular, the Commission finds that the proposed rule change is
consistent with Section 15A(b)(6) of the Act,\86\ which requires, among
other things, that FINRA rules be designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, and, in general, to protect investors and the
public interest.
---------------------------------------------------------------------------
\85\ In approving this proposal, the Commission has considered
the proposed rule's impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
\86\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
The Commission believes that the revisions to the Discovery Guide
will help reduce the number and limit the scope of disputes involving
document production and other matters, thereby improving the
arbitration process for the benefit of the public investors, broker-
dealer firms, and associated persons who use the process. The revisions
to the Discovery Guide are the result of over six years of consultation
by FINRA with its constituents. The Commission also expects that
further improvement of the process should be possible through the
Discovery Task Force's consideration of discovery issues as they
arise.\87\
---------------------------------------------------------------------------
\87\ Cf. Response Letter (describing plans for further
consideration of issues by the Discovery Task Force).
---------------------------------------------------------------------------
IV. Accelerated Approval
The Commission finds goods cause, pursuant to Section 19(b)(2) of
the Exchange Act,\88\ for approving the proposed rule change, as
modified by Amendment No. 1 thereto, prior to the 30th day after
publication of notice of the filing of Amendment No. 1 in the Federal
Register. The proposed rule change was informed by FINRA's
consideration of, and the incorporation of many suggestions made in,
extensive comments on a 2008 proposal to update the Discovery Guide,
and Amendment No. 1's modifications to the proposed rule change add
clarity to the Discovery Guide and provide additional guidance to
parties and arbitrators.
---------------------------------------------------------------------------
\88\ 15 U.S.C. 78s(b)(2).
---------------------------------------------------------------------------
Accordingly, the Commission finds that good cause exists to approve
the proposal, as modified by Amendment No. 1, on an accelerated basis.
V. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change, as modified by Amendment No. 1, is consistent with the Act.
Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number SR-FINRA-2010-035 on the subject line.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number SR-FINRA-2010-035. This
file number should be included on the subject line if e-mail is used.
To help the Commission process and review your comments more
efficiently, please use only one method. The Commission will post all
comments on the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments,
all written statements with respect to the proposed rule change that
are filed with the Commission, and all written communications relating
to the proposed rule change between the Commission and any person,
other than those that may be withheld from the public in accordance
with the provisions of 5 U.S.C. 552, will be available for Web site
viewing and printing in the Commission's Public Reference Room, 100 F
Street, NE., Washington, DC 20549, on official business days between
the hours of 10 a.m. and 3 p.m. Copies of such filing also will be
available for inspection and copying at the principal office of FINRA.
All comments received will be posted without change; the Commission
does not edit personal identifying information from submissions. You
should submit only information that you wish to make available
publicly. All submissions should refer to File Number SR-FINRA-2010-035
and should be submitted on or before April 27, 2011.
VI. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\89\ that the proposed rule change (SR-FINRA-2010-035), as modified
by Amendment No. 1, be, and hereby is, approved on an accelerated
basis.
---------------------------------------------------------------------------
\89\ 15 U.S.C. 78s(b)(2).
\90\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\90\
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011-8200 Filed 4-5-11; 8:45 am]
BILLING CODE 8011-01-P