Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of Proposed Rule Change to Adopt FINRA Rule 4524 (Supplemental FOCUS Information) and Proposed Supplementary Schedule to the Statement of Income (Loss) Page of FOCUS Reports, 70523-70527 [2011-29254]
Download as PDF
Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
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 the filing
also will be available for inspection and
copying at the principal office of the
Exchange. 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–Phlx–
2011–143 and should be submitted on
or before December 5, 2011.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.20
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2011–29300 Filed 11–10–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–65700; File No. SR–FINRA–
2011–064]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Proposed Rule Change to Adopt
FINRA Rule 4524 (Supplemental
FOCUS Information) and Proposed
Supplementary Schedule to the
Statement of Income (Loss) Page of
FOCUS Reports
mstockstill on DSK4VPTVN1PROD with NOTICES
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 November
1, 2011, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by FINRA. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
1. Purpose
Pursuant to SEA Rule 17a–5, members
are required to file with FINRA reports
concerning their financial and
operational status using SEC Form X–
17A–5, Financial and Operational
Combined Uniform Single (FOCUS)
Report.3 SEA Rule 17a-5 generally
requires members that clear transactions
or carry customer accounts to file a
FOCUS Report Part II, and requires
certain other members to file a FOCUS
Report Part IIA. Members that use
Appendix E to SEA Rule 15c3–1 to
calculate net capital file a FOCUS
Report Part II CSE 4 that is similar to the
FOCUS Report Part II (collectively, the
3 17
CFR 240.17a–5.
broker-dealer that calculates its net capital
under Appendix E of SEA Rule 15c3–1 is referred
to as Alternative Net Capital (‘‘ANC’’) firm.
20 17
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
19:40 Nov 10, 2011
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. FINRA has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
November 7, 2011.
VerDate Mar<15>2010
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
FINRA is proposing to adopt FINRA
Rule 4524 (Supplemental FOCUS
Information) to require each member, as
FINRA shall designate, to file such
additional financial or operational
schedules or reports as FINRA may
deem necessary as a supplement to the
FOCUS report. The content of such
supplemental schedules or reports
would be specified in a Regulatory
Notice (or similar communication),
which FINRA would file with the SEC
pursuant to proposed FINRA Rule 4524.
As part of the proposed rule change,
FINRA is filing one such proposed
schedule, a supplement to the Statement
of Income (Loss) page of the FOCUS
Report.
The text of the proposed rule change
is available on FINRA’s Web site at
https://www.finra.org, at the principal
office of FINRA and at the
Commission’s Public Reference Room.
4A
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70523
FOCUS Reports Part II, Part IIA, and
Part II CSE are referred to hereinafter as
‘‘FOCUS Reports’’).
FINRA is proposing to adopt FINRA
Rule 4524, a rule that would provide the
mechanism by which FINRA can obtain
from members more detailed financial
information to augment the FOCUS
reports required to be filed pursuant to
SEA Rule 17a–5. Proposed FINRA Rule
4524 would require members to file
such additional financial or operational
schedules or reports to supplement
FOCUS reports as FINRA may deem
necessary or appropriate for the
protection of investors or in the public
interest.5 Thus, the rule would provide
FINRA the framework to request more
specific information regarding, among
other things, the assets and liabilities of
a member, the generation of revenues
and allocation of expenses by business
segment or product lines, the sources of
trading gains and losses, the types and
amounts of fees earned, and the nature
and extent of participation in securities
offerings. Depending on the nature of
the proposed supplemental schedule or
report, FINRA may require that all
members or any specified subset of
members submit the schedule or report
to FINRA.
FOCUS Reports provide FINRA with
valuable information regarding a
member’s business; however, FINRA
believes that it can better discharge its
regulatory obligations with the benefit
of additional information that gives
FINRA a more complete and detailed
view of a member’s business operations.
Accordingly, proposed FINRA Rule
4524 would provide FINRA a means
and process to obtain greater
transparency into a member’s business
activities and to better illuminate
industry trends, allowing for more
focused and effective examinations.
FINRA would effectuate proposed
FINRA Rule 4524 by way of a
Regulatory Notice or similar
communication, the content of which
would be filed with the Commission. To
that end, as an initial report required
pursuant to proposed FINRA Rule 4524,
FINRA is also proposing a
Supplemental Statement of Income
(‘‘SSOI’’) to magnify the data from the
Statement of Income (Loss) page of the
FOCUS Reports.6
The proposed SSOI is intended to
capture more granular detail of a firm’s
revenue and expense information. The
lack of more specific revenue and
expense categories for certain business
5 Nothing in proposed FINRA Rule 4524 should
be construed as altering in any manner a member’s
obligations under SEA Rule 17a–5(a)(2)(iv).
6 See Exhibit 3.
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mstockstill on DSK4VPTVN1PROD with NOTICES
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Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
activities on the Statement of Income
(Loss) page of the FOCUS Reports has
led many firms to report much of their
revenue and expenses as ‘‘other’’
(miscellaneous), a very general
categorization that provides FINRA
limited visibility into revenue and
expense trends. The proposed SSOI is
divided into sections containing line
items that seek additional detail to
permit FINRA to better understand
revenue sources and expense
composition on an ongoing basis. This
additional detail would allow FINRA to
better assess risk at a firm, and as a
result, better allocate examination
resources. Each member would be
required to file with FINRA the
proposed SSOI within 17 business days
of the end of each calendar quarter.
The proposed SSOI contains a de
minimis exception for providing details
of revenue and expenses for certain
designated sections. If a member’s total
dollar amount for a designated section
is $5,000 or less for the reporting period,
the member would only be required to
enter the total dollar amount to
complete the section. Additionally, not
every line item would apply to every
member, especially those with limited
product offerings, thus limiting the
burden of completing the form.
The proposed SSOI includes a new
Operational Page that would collect
additional information from certain
members with respect to participation
in unregistered offerings during the
reporting period. Members whose
revenue from unregistered offerings
exceeds 10% of total revenue for the
reporting period would be required to
complete the Operational Page by
providing specific information about
each unregistered offering. FINRA
believes that such information would
provide it with greater transparency and
a stronger understanding regarding the
types of unregistered offerings that
generate significant revenue for
members.
The proposed rule change will be
effective upon Commission approval.
FINRA will announce the
implementation dates of both proposed
FINRA Rule 4524 and the proposed
schedule (i.e., the proposed SSOI) in a
Regulatory Notice to be published no
later than 60 days following
Commission approval of the proposed
rule change. The implementation date of
the proposed schedule will be no sooner
than 180 days, and no later than 365
days, following Commission approval of
the proposed rule change.
2. Statutory Basis
FINRA believes that the proposed rule
change is consistent with the provisions
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19:40 Nov 10, 2011
Jkt 226001
of Section 15A(b)(6) of the Act,7 which
requires, among other things, that
FINRA rules must 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. FINRA believes that the
proposed rule change is consistent with
the provisions of the Act noted above in
that supplemental FOCUS information
will further strengthen FINRA’s ability
to protect investors through a more
informed understanding of the drivers
of members’ business that can be used
for more targeted examinations.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
FINRA does not believe that the
proposed rule change will result in any
burden on competition that is not
necessary or appropriate in furtherance
of the purposes of the Act.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The proposed rule change and the
proposed SSOI were published for
comment in Regulatory Notice 10–33
(July 2010) (the ‘‘Notice’’). FINRA
received 28 comment letters in response
to the Notice.8 A copy of the Notice is
7 15
U.S.C. 78o–3(b)(6).
Letter from Ivy League Financial Services,
Inc., dated July 21, 2010 (‘‘Ivy’’); letter from M.S.
Howells & Co., dated July 23, 2010 (‘‘M.S.
Howells’’); letter from Hunter, Keith, Marshall &
Co., Inc, dated July 27, 2010 (‘‘HKM’’); letter from
Balanced Financial Securities, dated July 31, 2010
(‘‘BFS’’); letter from Foresters Equity Services, Inc.,
dated August 5, 2010 (‘‘FES’’); letter from Hodges
Capital Management-First Dallas Securities, dated
August 5, 2010 (‘‘HCM’’); letter from Farragut
Capital LLC, dated August 12, 2010 (‘‘Farragut’’);
letter from Integrity Investments, Inc., dated August
12, 2010 (‘‘Integrity’’); letter from Stephen Kinkade
CPA, dated August 15, 2010 (‘‘Kinkade’’); letter
from Wachtel & Co., Inc., dated August 16, 2010
(‘‘Wachtel’’); letter from First Asset Financial Inc.,
dated August 17, 2010 (‘‘FAF’’); letter from Aileen
Gallagher, dated August 17, 2010 (‘‘Gallagher’’);
letter from National Association of Independent
Broker-Dealers, Inc., dated August 17, 2010
(‘‘NAIBD’’); letter from Securities Industry and
Financial Markets Association, dated August 17,
2010 (‘‘SIFMA’’); letter from Wilson-Davis & Co.,
Inc., dated August 17, 2010 (‘‘WDC’’); letter from
Allegheny Investments, LTD, dated August 18, 2010
(‘‘Allegheny’’); letter from Berkshire Bridge Capital,
LLC, dated August 18, 2010 (‘‘Berkshire’’); letter
from IBG Trading Inc., dated August 18, 2010
(‘‘IBG’’); letter from Integrated Management
Solutions, dated August 18, 2010 (‘‘IMS’’); letter
from Probitas Partners, dated August 18, 2010
(‘‘Probitas’’); letter from Real Estate Investment
Securities Association, dated August 18, 2010
(‘‘REISA’’); letter from Regional Bond Dealers
Association, dated August 18, 2010 (‘‘RBDA’’);
letter from Sutherland Asbill & Brennan LLP, dated
August 18, 2010 (‘‘Sutherland’’); letter from
Southlake Capital Advisors, Inc., dated August 18,
2010 (‘‘SCA’’); letter from Trust Advisory Group,
Ltd., dated August 18, 2010 (‘‘TAG’’); letter from
8 See
PO 00000
Frm 00118
Fmt 4703
Sfmt 4703
attached as Exhibit 2a.9 A list of the
comment letters received in response to
the Notice is attached as Exhibit 2b.
Copies of the comment letters received
in response to the Notice are attached as
Exhibit 2c.10 Below is a summary of the
comments and FINRA’s responses.
A. Schedule Not Needed or Justified
A number of commenters argued that
the proposed SSOI is not needed or
justified.11 Some commenters stated
that FINRA or the SEC can already
request the information required by the
proposed SSOI.12 One commenter
believed that the current reports provide
sufficient detail for FINRA to
understand a member’s business.13 Two
commenters believed that routine exams
already give a detailed view of a
member’s business operations.14 Several
other commenters did not see how the
requested information protected
investors.15 Finally, one commenter
argued that FINRA has not justified why
the proposed SSOI is the best means of
achieving FINRA’s regulatory objectives
without undue burden on members.16
FINRA disagrees with the contentions
that the information sought is
unnecessary or superfluous. As stated in
the Notice, FINRA believes that it can
better discharge its regulatory
obligations with the benefit of
additional information that gives FINRA
a more complete and detailed view of a
member’s business operations.
Moreover, FINRA believes the proposed
SSOI is the most effective and timely
way to obtain the additional detail of
the generation of revenues and
allocation of expenses by business
segment or product lines, the sources of
trading gains and losses, the types and
Wedbush Securities Inc., dated August 18, 2010
(‘‘Wedbush’’); letter from Bank of America Merrill
Lynch, dated August 19, 2010 (‘‘B of A’’); and letter
from Citigroup Global Markets, Inc., dated August
20, 2010 (‘‘Citi’’).
9 The Commission notes that while provided in
Exhibit 2a to FINRA’s filing with the Commission,
the Notice is not attached hereto. The Notice can
be accessed online at https://www.finra.org/web/
groups/industry/@ip/@reg/@notice/documents/
notices/p121742.pdf.
10 The Commission notes that while provided in
Exhibit 2c to the filing, the list of the commenters
and comment letters received by FINRA are not
attached hereto. Those comment letters can be
accessed online at https://www.finra.org/Industry/
Regulation/Notices/2010/P121743. As stated
previously, all references to ‘‘commenters’’ are to
the commenters to the Notice, which are listed in
Exhibit 2b.
11 Allegheny, FAF, Farragut, Integrity, Ivy,
Kinkade, Probitas, REISA, Sutherland and WDC.
12 Allegheny, Sutherland, Farragut, Integrity and
Kinkade.
13 Ivy.
14 REISA and WDC.
15 Farragut, Kinkade, Probitas and WDC.
16 RBDA.
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Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
amounts of fees earned, and the nature
and extent of participation in securities
offerings.
B. Small Firm Concerns
Several commenters stated that the
proposed SSOI will be costly and time
consuming for small firms.17 Some of
these commenters argued that FINRA
should provide an exemption from the
rule for smaller firms.18 Several
commenters asserted that the
Operational Page creates an unfair bias
against smaller firms.19 FINRA believes
that the required information is
important to identify regulatory risk and
trends, irrespective of firm size.
Therefore, FINRA does not believe a
small firm exemption is appropriate.
However, as mentioned above, the
proposed SSOI contains a de minimis
exception that will make the form less
time consuming for many smaller firms.
Additionally, FINRA points out that
many of the line items will not apply to
smaller firms with limited product
offerings.
mstockstill on DSK4VPTVN1PROD with NOTICES
C. Clarifications and Recommended
Changes
Certain commenters requested
clarification of the information required
on the proposed SSOI.20 Several
commenters suggested that FINRA
should include instructions and
definitions for the proposed SSOI.21
One commenter had concerns that the
‘‘numbers reported on the FOCUS
Report and the Proposed Schedule will
not automatically ‘match.’ ’’ 22 Further,
several commenters recommended
changes to specific line items on the
proposed SSOI.23 In response to these
comments, FINRA has developed
instructions for the proposed SSOI,
which are included in the attached
Exhibit 3. The instructions include
guidance, clarifications and definitions
with respect to certain line items that
FINRA believes should ameliorate the
commenters’ concerns. Additionally, in
response to recommended changes to
specific line items, FINRA has amended
the proposed SSOI by making the
requested tax information less
burdensome, allowing flexibility
regarding the reporting of dividends and
interest for principal trades and
17 Allegheny, BFS, FAF, Farragut, FES, Gallagher,
HCM, HKM, IMS, Integrity, Kinkade, M.S. Howells,
Probitas, RBDA, REISA, TAG, Wachtel and WDC.
18 BFS, HKM, Wachtel and WDC.
19 HKM, Kinkade, NAIBD and REISA.
20 Allegheny, B of A, Citi, FAF, IMS, Kinkade,
NAIBD, RBDA, Sutherland and WDC.
21 Citi, IMS, Kinkade, NAIBD, RBDA and
Sutherland.
22 Sutherland.
23 B of A, IMS and Kinkade.
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19:40 Nov 10, 2011
Jkt 226001
allowing revenue from unit investment
trusts that are open-end companies to be
included with revenue from investment
company shares.
D. Data Capture
Several commenters suggested that
the profit and loss information required
by the proposed SSOI should be based
on established units within a firm rather
than by product.24 In response, FINRA
believes that requiring information by
product is the best way to understand
revenue sources and expense
composition. However, FINRA is
allowing firms, in certain instances, a
choice as to which section and/or line
item on the proposed SSOI to reflect
revenue or expense. Firms must
document the methodology chosen and
apply it consistently across reporting
periods. Additionally, the methodology
must be made available to FINRA staff
upon request.
E. Confidentiality
One commenter expressed
competitive concerns with providing
FINRA detailed departmental data.25
Another commenter was concerned that
the proposed SSOI could compromise
otherwise confidential deal making.26
The commenter stated that members
‘‘specializing in restructuring/distressed
situations are frequently bound to
confidentiality by U.S. bankruptcy laws
that would preclude the release of
certain information.’’ 27 FINRA does not
believe these concerns are valid as the
proposed SSOI would be treated with
the same confidentiality as the FOCUS
Report to which it relates.28 In regard to
the commenter’s concern about being
bound to confidentiality by U.S.
bankruptcy laws, FINRA notes that the
commenter did not provide any specific
examples of such U.S. bankruptcy laws
or discussion of the manner in which
such laws would preclude a member
from complying with the proposed
rulemaking.
F. Use of the Proposed SSOI
Several commenters were concerned
that the proposed SSOI would be used
as the basis for the calculation of
various assessments, fees and dues on
members.29 As previously mentioned,
the proposed SSOI is intended to
provide information about a member’s
revenue and expenses in greater detail.
The proposed SSOI supplements the
24 B of A, Citi, IMS, Kinkade, M.S. Howells and
SIFMA.
25 M.S. Howells.
26 NAIBD.
27 NAIBD.
28 See SEA Rule 17a–5(a)(3).
29 B of A, BBC, SIFMA and Wedbush.
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Fmt 4703
Sfmt 4703
70525
FOCUS report and would not be used as
the basis for any assessments, fees or
dues; however, total revenue on the
proposed SSOI should equal total
revenue on the FOCUS report.
G. Reporting Period
Several commenters recommended
that reporting of the proposed SSOI be
on a quarterly basis.30 These
commenters stated that ‘‘[m]any firms as
a matter of course have more detailed
reporting requirements—both internal
and external—on a quarterly basis,
which would facilitate this additional
FINRA reporting while limiting the
need for additional resources.’’ 31
FINRA agrees with the commenters and
has proposed quarterly basis reporting
for the proposed SSOI.
H. Filing Time Frame
Two commenters suggested that the
proposed SSOI should be filed within
the time frames for current
supplemental reporting and not on the
FOCUS filing date.32 They believed that
filing within such time frames would
address resource constraints and would
be consistent with other reporting time
frames. FINRA disagrees with the
commenters and instead has proposed
to require the proposed SSOI to be filed
within 17 business days after the end of
the calendar quarter, consistent with the
time frame allowed for the filing of the
FOCUS Reports. FINRA believes that
this time frame strikes the proper
balance of ensuring FINRA receives
timely information while giving firms’
sufficient time to file the proposed
SSOI.
I. Operational Page of the Proposed
SSOI
Several commenters believed that
FINRA is unfairly targeting Regulation D
offerings.33 One commenter suggested
that the Operational Page only apply to
all offerings that exceed a fixed dollar
amount, rather than offerings in excess
of 10% of total revenue.34 Another
commenter stated that the information
requested by the Operational Page for
firm underwriting and selling group
arrangements is identical to the
information requested following a blue
sheet transaction.35 The commenter
urged that if the proposed SSOI is
incorporated as represented, FINRA
cease routinely requiring firms to
provide identical information for firm
underwriting and selling group
30 B
of A and SIFMA.
of A and SIFMA.
32 B of A and SIFMA.
33 Farragut and REISA.
34 Kinkade.
35 NAIBD.
31 B
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arrangements following a blue-sheet
transaction.36 Finally, one commenter
stated that Operational Page reporting
should be disassociated with financial
reporting for any member filing FOCUS
Report Part IIA (not filing FOCUS
Report Part II) by having its own format,
frequency and deadline schedule.37
FINRA believes the Operational Page
of the proposed SSOI would provide
greater transparency and valuable
information regarding unregistered
offerings. A fixed dollar amount
threshold would be inappropriate as
FINRA needs to capture revenue that is
significant to the member. Members that
exceed the 10% of total revenue
threshold are considered to be obtaining
significant revenue from unregistered
offerings. Additionally, the information
requested from the Operational Page is
not identical to the information
requested in a blue sheet transaction.38
Finally, the Operational Page is part of
the proposed SSOI, and therefore would
be subject to the same frequency and
deadline schedule of the proposed
SSOI.
J. Implementation
Several commenters requested that
FINRA provide sufficient lead time for
members to prepare for the new rule.39
A number of commenters stated system
changes would be needed to capture the
requested information.40 One
commenter suggested that the
implementation of the proposed SSOI
be staged as a series of pilots, beginning
with clearing firms, then gradually
covering the membership by firm size.41
FINRA is sensitive to the operational
and systems changes that may be
necessary for members to complete the
proposed SSOI, and as a result, is
proposing to implement the SSOI no
sooner than 180 days, and no later than
365 days, following Commission
approval of the proposed rule change.
mstockstill on DSK4VPTVN1PROD with NOTICES
K. Alternatives to Schedule
A number of commenters offered
alternatives to the proposed SSOI.42
Several commenters suggested that more
detailed information should not be
required unless the particular line item
represents a specified percentage of a
firm’s business or at least a dollar
amount threshold.43 One commenter
suggested that FINRA consider requiring
36 NAIBD.
37 Kinkade.
SEA Rule 17a–25.
RBDA and SIFMA.
40 Citi, FAF, HCM, M.S. Howells, NAIBD, RBDA
and SIFMA.
41 NAIBD.
42 Allegheny, NAIBD, Sutherland and Wachtel.
43 NAIBD, Sutherland and Wachtel.
that the information requested by the
proposed SSOI be submitted annually
with the audit report.44 Another
commenter believed that instead of
adopting the proposed SSOI, FINRA
should meet with members to discuss
whether a new regulatory report is
needed; what format works best with
the FOCUS Report; and consider the
costs of implementing a system.45
FINRA has considered these alternatives
and believes that obtaining information
regarding the detail of revenues earned
or expenses incurred by product or
other more specific categories is best
achieved through the proposed SSOI.
FINRA notes that it consulted with its
advisory committees in connection with
the development of the proposed SSOI.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
L. New Financial and Operational
Reports or Schedules
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Several commenters suggested that
any new financial or operational report
or schedule required by FINRA be
submitted to the SEC as a proposed rule
change to allow members an
opportunity to provide FINRA with
feedback.46 One commenter suggested
that such submission is necessary due to
possible conflicts that FINRA schedules
and reports may have with other laws
and rules.47 Another commenter argued
that the opportunity for member
comment is needed because specific
line items may be missing or irrelevant
over time.48
As stated above, pursuant to proposed
FINRA Rule 4524, FINRA will file with
the SEC the content of any Regulatory
Notice (or similar communication)
issued pursuant to the proposed rule.
Further, if such content contains
material substantive changes, FINRA
will file the content for comment with
the SEC. Commenters will have an
opportunity to express their concerns
and provide feedback at that time.
M. Comment Period
One commenter expressed
disappointment that the comment
period ended the same day FINRA sent
the Notice.49 The commenter believed
that FINRA did not give the public
ample opportunity to study the matter.
FINRA believes the commenter is
mistaken as the Notice was issued on
July 19, 2010, requesting comment until
August 18, 2010.
38 See
39 Citi,
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19:40 Nov 10, 2011
Jkt 226001
44 Allegheny.
45 Sutherland.
46 IMS,
NAIBD, RBDA and Sutherland.
47 Sutherland.
48 NAIBD.
49 SCA.
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Sfmt 4703
Within 45 days of the date of
publication of this notice in the Federal
Register or within such longer period (i)
as the Commission may designate up to
90 days of such date if it finds such
longer period to be appropriate and
publishes its reasons for so finding or
(ii) as to which the self-regulatory
organization consents, the Commission
will:
(A) By order approve or disapprove
such proposed rule change, or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
IV. Solicitation of Comments
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–FINRA–2011–064 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–2011–064. This file
number should be included on the
subject line if email 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
E:\FR\FM\14NON1.SGM
14NON1
Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
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–2011–064 and
should be submitted on or before
December 5, 2011.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.50
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2011–29254 Filed 11–10–11; 8:45 am]
BILLING CODE 8011–01–P
SMALL BUSINESS ADMINISTRATION
Reporting and Recordkeeping
Requirements Under OMB Review
Small Business Administration.
Notice of Reporting
Requirements Submitted for OMB
Review.
AGENCY:
ACTION:
Under the provisions of the
Paperwork Reduction Act (44 U.S.C.
Chapter 35), agencies are required to
submit proposed reporting and
recordkeeping requirements to OMB for
review and approval, and to publish a
notice in the Federal Register notifying
the public that the agency has made
such a submission.
DATES: Submit comments on or before
December 14, 2011. If you intend to
comment but cannot prepare comments
promptly, please advise the OMB
Reviewer and the Agency Clearance
Officer before the deadline.
Copies: Request for clearance (OMB
83–1), supporting statement, and other
documents submitted to OMB for
review may be obtained from the
Agency Clearance Officer.
ADDRESSES: Address all comments
concerning this notice to: Agency
Clearance Officer, Jacqueline White,
Small Business Administration, 409 3rd
Street SW., 5th Floor, Washington, DC
20416; and OMB Reviewer, Office of
Information and Regulatory Affairs,
Office of Management and Budget, New
Executive Office Building, Washington,
DC 20503.
FOR FURTHER INFORMATION CONTACT:
Jacqueline White, Agency Clearance
Officer, (202) 205–7044.
mstockstill on DSK4VPTVN1PROD with NOTICES
SUMMARY:
SUPPLEMENTARY INFORMATION:
SMALL BUSINESS ADMINISTRATION
Title: ‘‘25–Model Corp.Resol.or GP
Certif.33–Model Letter to Selling Agent.
34–Bank ID, 1065–Appl.Lic.Assure of
Compliance.
Form No’s: 23, 33, 34, 1065.
Frequency: On Occasion.
Description of Respondents:
Application for SBA-guaranteed
leverages.
Responses: 48.
Annual Burden: 42.
Title: ‘‘U.S. Small Business Advisory
Committee Membership Information’’.
Form No: 898.
Frequency: On Occasion.
Description of Respondents: To
collect information for Candidates for
Advisory Council.
Responses: 100.
Annual Burden: 100.
Title: ‘‘Financial Statement of
Debtor’’.
Form No: 770.
Frequency: On Occasion.
Description of Respondents: SBA
Borrowers or guarantor’s who request
compromise.
Responses: 5,000.
Annual Burden: 2,500.
Title: ‘‘Lender’s Transcript of
Account’’.
Form No: 1149.
Frequency: On Occasion.
Description of Respondents: SBA
Borrowers to complete loan
authorization.
Responses: 3,600.
Annual Burden: 3,600.
Title: ‘‘New Markets Venture Capital
Program Application Funding and
Reporting’’.
Form No’s: 2216, 2185, 2219, 2210,
468.1, 480
Frequency: On Occasion.
Description of Respondents: Programs
Application and participants, SSBIC
receiving grants under the NMVC
program.
Responses: 1,151.
Annual Burden: 14,012.
Title: ‘‘Settlement Sheet’’.
Form No: 1050.
Frequency: On Occasion.
Description of Respondents: Lenders
requesting SBA to provide the Agency
with breakdown of payments.
Responses: 19,800.
Annual Burden: 4,950.
Jacqueline White,
Chief, Administrative Information Branch.
[FR Doc. 2011–29209 Filed 11–10–11; 8:45 am]
50 17
CFR 200.30–3(a)(12).
VerDate Mar<15>2010
19:40 Nov 10, 2011
BILLING CODE P
Jkt 226001
PO 00000
Frm 00121
Fmt 4703
Sfmt 4703
70527
[Disaster Declaration #12820 and #12821]
Pennsylvania Disaster Number PA–
00042
U.S. Small Business
Administration.
ACTION: Amendment 1.
AGENCY:
This is an amendment of the
Presidential declaration of a major
disaster for the State of Pennsylvania
(FEMA–4025–DR), dated 09/12/2011 .
Incident: Hurricane Irene.
Incident Period: 08/26/2011 through
08/30/2011.
DATES: Effective Date: 11/04/2011.
Physical Loan Application Deadline
Date: 12/14/2011.
Eidl Loan Application Deadline Date:
06/12/2012.
ADDRESSES: Submit completed loan
applications to: U.S. Small Business
Administration, Processing and
Disbursement Center, 14925 Kingsport
Road, Fort Worth, TX 76155.
FOR FURTHER INFORMATION CONTACT: A
Escobar, Office of Disaster Assistance,
U.S. Small Business Administration,
409 3rd Street SW., Suite 6050,
Washington, DC 20416.
SUPPLEMENTARY INFORMATION: The notice
of the President’s major disaster
declaration for the State of
Pennsylvania, dated 09/12/2011 is
hereby amended to extend the deadline
for filing applications for physical
damages as a result of this disaster to
12/14/2011.
All other information in the original
declaration remains unchanged.
SUMMARY:
(Catalog of Federal Domestic Assistance
Numbers 59002 and 59008)
James E. Rivera Associate,
Administrator for Disaster Assistance.
[FR Doc. 2011–29215 Filed 11–10–11; 8:45 am]
BILLING CODE 8025–01–P
SMALL BUSINESS ADMINISTRATION
[Disaster Declaration #12874 and #12875]
Maryland Disaster Number MD–00018
U.S. Small Business
Administration.
ACTION: Amendment 1.
AGENCY:
This is an amendment of the
Presidential declaration of a major
disaster for Public Assistance Only for
the State of Maryland (FEMA–4038–
DR), dated 10/05/2011.
Incident: Remnants of Tropical Storm
Lee.
Incident Period: 09/06/2011 through
09/09/2011.
SUMMARY:
E:\FR\FM\14NON1.SGM
14NON1
Agencies
[Federal Register Volume 76, Number 219 (Monday, November 14, 2011)]
[Notices]
[Pages 70523-70527]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-29254]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-65700; File No. SR-FINRA-2011-064]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of Proposed Rule Change to Adopt
FINRA Rule 4524 (Supplemental FOCUS Information) and Proposed
Supplementary Schedule to the Statement of Income (Loss) Page of FOCUS
Reports
November 7, 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 November 1, 2011, Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission (``SEC''
or ``Commission'') the proposed rule change as described in Items I,
II, and III below, which Items have been prepared by FINRA. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
FINRA is proposing to adopt FINRA Rule 4524 (Supplemental FOCUS
Information) to require each member, as FINRA shall designate, to file
such additional financial or operational schedules or reports as FINRA
may deem necessary as a supplement to the FOCUS report. The content of
such supplemental schedules or reports would be specified in a
Regulatory Notice (or similar communication), which FINRA would file
with the SEC pursuant to proposed FINRA Rule 4524. As part of the
proposed rule change, FINRA is filing one such proposed schedule, a
supplement to the Statement of Income (Loss) page of the FOCUS Report.
The text of the proposed rule change is available on FINRA's Web
site at https://www.finra.org, at the principal office of FINRA and at
the Commission's Public Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, FINRA included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. FINRA has prepared summaries, set forth in sections A,
B, and C below, of the most significant aspects of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
Pursuant to SEA Rule 17a-5, members are required to file with FINRA
reports concerning their financial and operational status using SEC
Form X-17A-5, Financial and Operational Combined Uniform Single (FOCUS)
Report.\3\ SEA Rule 17a-5 generally requires members that clear
transactions or carry customer accounts to file a FOCUS Report Part II,
and requires certain other members to file a FOCUS Report Part IIA.
Members that use Appendix E to SEA Rule 15c3-1 to calculate net capital
file a FOCUS Report Part II CSE \4\ that is similar to the FOCUS Report
Part II (collectively, the FOCUS Reports Part II, Part IIA, and Part II
CSE are referred to hereinafter as ``FOCUS Reports'').
---------------------------------------------------------------------------
\3\ 17 CFR 240.17a-5.
\4\ A broker-dealer that calculates its net capital under
Appendix E of SEA Rule 15c3-1 is referred to as Alternative Net
Capital (``ANC'') firm.
---------------------------------------------------------------------------
FINRA is proposing to adopt FINRA Rule 4524, a rule that would
provide the mechanism by which FINRA can obtain from members more
detailed financial information to augment the FOCUS reports required to
be filed pursuant to SEA Rule 17a-5. Proposed FINRA Rule 4524 would
require members to file such additional financial or operational
schedules or reports to supplement FOCUS reports as FINRA may deem
necessary or appropriate for the protection of investors or in the
public interest.\5\ Thus, the rule would provide FINRA the framework to
request more specific information regarding, among other things, the
assets and liabilities of a member, the generation of revenues and
allocation of expenses by business segment or product lines, the
sources of trading gains and losses, the types and amounts of fees
earned, and the nature and extent of participation in securities
offerings. Depending on the nature of the proposed supplemental
schedule or report, FINRA may require that all members or any specified
subset of members submit the schedule or report to FINRA.
---------------------------------------------------------------------------
\5\ Nothing in proposed FINRA Rule 4524 should be construed as
altering in any manner a member's obligations under SEA Rule 17a-
5(a)(2)(iv).
---------------------------------------------------------------------------
FOCUS Reports provide FINRA with valuable information regarding a
member's business; however, FINRA believes that it can better discharge
its regulatory obligations with the benefit of additional information
that gives FINRA a more complete and detailed view of a member's
business operations. Accordingly, proposed FINRA Rule 4524 would
provide FINRA a means and process to obtain greater transparency into a
member's business activities and to better illuminate industry trends,
allowing for more focused and effective examinations.
FINRA would effectuate proposed FINRA Rule 4524 by way of a
Regulatory Notice or similar communication, the content of which would
be filed with the Commission. To that end, as an initial report
required pursuant to proposed FINRA Rule 4524, FINRA is also proposing
a Supplemental Statement of Income (``SSOI'') to magnify the data from
the Statement of Income (Loss) page of the FOCUS Reports.\6\
---------------------------------------------------------------------------
\6\ See Exhibit 3.
---------------------------------------------------------------------------
The proposed SSOI is intended to capture more granular detail of a
firm's revenue and expense information. The lack of more specific
revenue and expense categories for certain business
[[Page 70524]]
activities on the Statement of Income (Loss) page of the FOCUS Reports
has led many firms to report much of their revenue and expenses as
``other'' (miscellaneous), a very general categorization that provides
FINRA limited visibility into revenue and expense trends. The proposed
SSOI is divided into sections containing line items that seek
additional detail to permit FINRA to better understand revenue sources
and expense composition on an ongoing basis. This additional detail
would allow FINRA to better assess risk at a firm, and as a result,
better allocate examination resources. Each member would be required to
file with FINRA the proposed SSOI within 17 business days of the end of
each calendar quarter.
The proposed SSOI contains a de minimis exception for providing
details of revenue and expenses for certain designated sections. If a
member's total dollar amount for a designated section is $5,000 or less
for the reporting period, the member would only be required to enter
the total dollar amount to complete the section. Additionally, not
every line item would apply to every member, especially those with
limited product offerings, thus limiting the burden of completing the
form.
The proposed SSOI includes a new Operational Page that would
collect additional information from certain members with respect to
participation in unregistered offerings during the reporting period.
Members whose revenue from unregistered offerings exceeds 10% of total
revenue for the reporting period would be required to complete the
Operational Page by providing specific information about each
unregistered offering. FINRA believes that such information would
provide it with greater transparency and a stronger understanding
regarding the types of unregistered offerings that generate significant
revenue for members.
The proposed rule change will be effective upon Commission
approval. FINRA will announce the implementation dates of both proposed
FINRA Rule 4524 and the proposed schedule (i.e., the proposed SSOI) in
a Regulatory Notice to be published no later than 60 days following
Commission approval of the proposed rule change. The implementation
date of the proposed schedule will be no sooner than 180 days, and no
later than 365 days, following Commission approval of the proposed rule
change.
2. Statutory Basis
FINRA believes that the proposed rule change is consistent with the
provisions of Section 15A(b)(6) of the Act,\7\ which requires, among
other things, that FINRA rules must 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. FINRA believes that the proposed rule change is
consistent with the provisions of the Act noted above in that
supplemental FOCUS information will further strengthen FINRA's ability
to protect investors through a more informed understanding of the
drivers of members' business that can be used for more targeted
examinations.
---------------------------------------------------------------------------
\7\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
B. Self-Regulatory Organization's Statement on Burden on Competition
FINRA does not believe that the proposed rule change will result in
any burden on competition that is not necessary or appropriate in
furtherance of the purposes of the Act.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
The proposed rule change and the proposed SSOI were published for
comment in Regulatory Notice 10-33 (July 2010) (the ``Notice''). FINRA
received 28 comment letters in response to the Notice.\8\ A copy of the
Notice is attached as Exhibit 2a.\9\ A list of the comment letters
received in response to the Notice is attached as Exhibit 2b. Copies of
the comment letters received in response to the Notice are attached as
Exhibit 2c.\10\ Below is a summary of the comments and FINRA's
responses.
---------------------------------------------------------------------------
\8\ See Letter from Ivy League Financial Services, Inc., dated
July 21, 2010 (``Ivy''); letter from M.S. Howells & Co., dated July
23, 2010 (``M.S. Howells''); letter from Hunter, Keith, Marshall &
Co., Inc, dated July 27, 2010 (``HKM''); letter from Balanced
Financial Securities, dated July 31, 2010 (``BFS''); letter from
Foresters Equity Services, Inc., dated August 5, 2010 (``FES'');
letter from Hodges Capital Management-First Dallas Securities, dated
August 5, 2010 (``HCM''); letter from Farragut Capital LLC, dated
August 12, 2010 (``Farragut''); letter from Integrity Investments,
Inc., dated August 12, 2010 (``Integrity''); letter from Stephen
Kinkade CPA, dated August 15, 2010 (``Kinkade''); letter from
Wachtel & Co., Inc., dated August 16, 2010 (``Wachtel''); letter
from First Asset Financial Inc., dated August 17, 2010 (``FAF'');
letter from Aileen Gallagher, dated August 17, 2010 (``Gallagher'');
letter from National Association of Independent Broker-Dealers,
Inc., dated August 17, 2010 (``NAIBD''); letter from Securities
Industry and Financial Markets Association, dated August 17, 2010
(``SIFMA''); letter from Wilson-Davis & Co., Inc., dated August 17,
2010 (``WDC''); letter from Allegheny Investments, LTD, dated August
18, 2010 (``Allegheny''); letter from Berkshire Bridge Capital, LLC,
dated August 18, 2010 (``Berkshire''); letter from IBG Trading Inc.,
dated August 18, 2010 (``IBG''); letter from Integrated Management
Solutions, dated August 18, 2010 (``IMS''); letter from Probitas
Partners, dated August 18, 2010 (``Probitas''); letter from Real
Estate Investment Securities Association, dated August 18, 2010
(``REISA''); letter from Regional Bond Dealers Association, dated
August 18, 2010 (``RBDA''); letter from Sutherland Asbill & Brennan
LLP, dated August 18, 2010 (``Sutherland''); letter from Southlake
Capital Advisors, Inc., dated August 18, 2010 (``SCA''); letter from
Trust Advisory Group, Ltd., dated August 18, 2010 (``TAG''); letter
from Wedbush Securities Inc., dated August 18, 2010 (``Wedbush'');
letter from Bank of America Merrill Lynch, dated August 19, 2010
(``B of A''); and letter from Citigroup Global Markets, Inc., dated
August 20, 2010 (``Citi'').
\9\ The Commission notes that while provided in Exhibit 2a to
FINRA's filing with the Commission, the Notice is not attached
hereto. The Notice can be accessed online at https://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p121742.pdf.
\10\ The Commission notes that while provided in Exhibit 2c to
the filing, the list of the commenters and comment letters received
by FINRA are not attached hereto. Those comment letters can be
accessed online at https://www.finra.org/Industry/Regulation/Notices/2010/P121743. As stated previously, all references to ``commenters''
are to the commenters to the Notice, which are listed in Exhibit 2b.
---------------------------------------------------------------------------
A. Schedule Not Needed or Justified
A number of commenters argued that the proposed SSOI is not needed
or justified.\11\ Some commenters stated that FINRA or the SEC can
already request the information required by the proposed SSOI.\12\ One
commenter believed that the current reports provide sufficient detail
for FINRA to understand a member's business.\13\ Two commenters
believed that routine exams already give a detailed view of a member's
business operations.\14\ Several other commenters did not see how the
requested information protected investors.\15\ Finally, one commenter
argued that FINRA has not justified why the proposed SSOI is the best
means of achieving FINRA's regulatory objectives without undue burden
on members.\16\ FINRA disagrees with the contentions that the
information sought is unnecessary or superfluous. As stated in the
Notice, FINRA believes that it can better discharge its regulatory
obligations with the benefit of additional information that gives FINRA
a more complete and detailed view of a member's business operations.
Moreover, FINRA believes the proposed SSOI is the most effective and
timely way to obtain the additional detail of the generation of
revenues and allocation of expenses by business segment or product
lines, the sources of trading gains and losses, the types and
[[Page 70525]]
amounts of fees earned, and the nature and extent of participation in
securities offerings.
---------------------------------------------------------------------------
\11\ Allegheny, FAF, Farragut, Integrity, Ivy, Kinkade,
Probitas, REISA, Sutherland and WDC.
\12\ Allegheny, Sutherland, Farragut, Integrity and Kinkade.
\13\ Ivy.
\14\ REISA and WDC.
\15\ Farragut, Kinkade, Probitas and WDC.
\16\ RBDA.
---------------------------------------------------------------------------
B. Small Firm Concerns
Several commenters stated that the proposed SSOI will be costly and
time consuming for small firms.\17\ Some of these commenters argued
that FINRA should provide an exemption from the rule for smaller
firms.\18\ Several commenters asserted that the Operational Page
creates an unfair bias against smaller firms.\19\ FINRA believes that
the required information is important to identify regulatory risk and
trends, irrespective of firm size. Therefore, FINRA does not believe a
small firm exemption is appropriate. However, as mentioned above, the
proposed SSOI contains a de minimis exception that will make the form
less time consuming for many smaller firms. Additionally, FINRA points
out that many of the line items will not apply to smaller firms with
limited product offerings.
---------------------------------------------------------------------------
\17\ Allegheny, BFS, FAF, Farragut, FES, Gallagher, HCM, HKM,
IMS, Integrity, Kinkade, M.S. Howells, Probitas, RBDA, REISA, TAG,
Wachtel and WDC.
\18\ BFS, HKM, Wachtel and WDC.
\19\ HKM, Kinkade, NAIBD and REISA.
---------------------------------------------------------------------------
C. Clarifications and Recommended Changes
Certain commenters requested clarification of the information
required on the proposed SSOI.\20\ Several commenters suggested that
FINRA should include instructions and definitions for the proposed
SSOI.\21\ One commenter had concerns that the ``numbers reported on the
FOCUS Report and the Proposed Schedule will not automatically `match.'
'' \22\ Further, several commenters recommended changes to specific
line items on the proposed SSOI.\23\ In response to these comments,
FINRA has developed instructions for the proposed SSOI, which are
included in the attached Exhibit 3. The instructions include guidance,
clarifications and definitions with respect to certain line items that
FINRA believes should ameliorate the commenters' concerns.
Additionally, in response to recommended changes to specific line
items, FINRA has amended the proposed SSOI by making the requested tax
information less burdensome, allowing flexibility regarding the
reporting of dividends and interest for principal trades and allowing
revenue from unit investment trusts that are open-end companies to be
included with revenue from investment company shares.
---------------------------------------------------------------------------
\20\ Allegheny, B of A, Citi, FAF, IMS, Kinkade, NAIBD, RBDA,
Sutherland and WDC.
\21\ Citi, IMS, Kinkade, NAIBD, RBDA and Sutherland.
\22\ Sutherland.
\23\ B of A, IMS and Kinkade.
---------------------------------------------------------------------------
D. Data Capture
Several commenters suggested that the profit and loss information
required by the proposed SSOI should be based on established units
within a firm rather than by product.\24\ In response, FINRA believes
that requiring information by product is the best way to understand
revenue sources and expense composition. However, FINRA is allowing
firms, in certain instances, a choice as to which section and/or line
item on the proposed SSOI to reflect revenue or expense. Firms must
document the methodology chosen and apply it consistently across
reporting periods. Additionally, the methodology must be made available
to FINRA staff upon request.
---------------------------------------------------------------------------
\24\ B of A, Citi, IMS, Kinkade, M.S. Howells and SIFMA.
---------------------------------------------------------------------------
E. Confidentiality
One commenter expressed competitive concerns with providing FINRA
detailed departmental data.\25\ Another commenter was concerned that
the proposed SSOI could compromise otherwise confidential deal
making.\26\ The commenter stated that members ``specializing in
restructuring/distressed situations are frequently bound to
confidentiality by U.S. bankruptcy laws that would preclude the release
of certain information.'' \27\ FINRA does not believe these concerns
are valid as the proposed SSOI would be treated with the same
confidentiality as the FOCUS Report to which it relates.\28\ In regard
to the commenter's concern about being bound to confidentiality by U.S.
bankruptcy laws, FINRA notes that the commenter did not provide any
specific examples of such U.S. bankruptcy laws or discussion of the
manner in which such laws would preclude a member from complying with
the proposed rulemaking.
---------------------------------------------------------------------------
\25\ M.S. Howells.
\26\ NAIBD.
\27\ NAIBD.
\28\ See SEA Rule 17a-5(a)(3).
---------------------------------------------------------------------------
F. Use of the Proposed SSOI
Several commenters were concerned that the proposed SSOI would be
used as the basis for the calculation of various assessments, fees and
dues on members.\29\ As previously mentioned, the proposed SSOI is
intended to provide information about a member's revenue and expenses
in greater detail. The proposed SSOI supplements the FOCUS report and
would not be used as the basis for any assessments, fees or dues;
however, total revenue on the proposed SSOI should equal total revenue
on the FOCUS report.
---------------------------------------------------------------------------
\29\ B of A, BBC, SIFMA and Wedbush.
---------------------------------------------------------------------------
G. Reporting Period
Several commenters recommended that reporting of the proposed SSOI
be on a quarterly basis.\30\ These commenters stated that ``[m]any
firms as a matter of course have more detailed reporting requirements--
both internal and external--on a quarterly basis, which would
facilitate this additional FINRA reporting while limiting the need for
additional resources.'' \31\ FINRA agrees with the commenters and has
proposed quarterly basis reporting for the proposed SSOI.
---------------------------------------------------------------------------
\30\ B of A and SIFMA.
\31\ B of A and SIFMA.
---------------------------------------------------------------------------
H. Filing Time Frame
Two commenters suggested that the proposed SSOI should be filed
within the time frames for current supplemental reporting and not on
the FOCUS filing date.\32\ They believed that filing within such time
frames would address resource constraints and would be consistent with
other reporting time frames. FINRA disagrees with the commenters and
instead has proposed to require the proposed SSOI to be filed within 17
business days after the end of the calendar quarter, consistent with
the time frame allowed for the filing of the FOCUS Reports. FINRA
believes that this time frame strikes the proper balance of ensuring
FINRA receives timely information while giving firms' sufficient time
to file the proposed SSOI.
---------------------------------------------------------------------------
\32\ B of A and SIFMA.
---------------------------------------------------------------------------
I. Operational Page of the Proposed SSOI
Several commenters believed that FINRA is unfairly targeting
Regulation D offerings.\33\ One commenter suggested that the
Operational Page only apply to all offerings that exceed a fixed dollar
amount, rather than offerings in excess of 10% of total revenue.\34\
Another commenter stated that the information requested by the
Operational Page for firm underwriting and selling group arrangements
is identical to the information requested following a blue sheet
transaction.\35\ The commenter urged that if the proposed SSOI is
incorporated as represented, FINRA cease routinely requiring firms to
provide identical information for firm underwriting and selling group
[[Page 70526]]
arrangements following a blue-sheet transaction.\36\ Finally, one
commenter stated that Operational Page reporting should be
disassociated with financial reporting for any member filing FOCUS
Report Part IIA (not filing FOCUS Report Part II) by having its own
format, frequency and deadline schedule.\37\
---------------------------------------------------------------------------
\33\ Farragut and REISA.
\34\ Kinkade.
\35\ NAIBD.
\36\ NAIBD.
\37\ Kinkade.
---------------------------------------------------------------------------
FINRA believes the Operational Page of the proposed SSOI would
provide greater transparency and valuable information regarding
unregistered offerings. A fixed dollar amount threshold would be
inappropriate as FINRA needs to capture revenue that is significant to
the member. Members that exceed the 10% of total revenue threshold are
considered to be obtaining significant revenue from unregistered
offerings. Additionally, the information requested from the Operational
Page is not identical to the information requested in a blue sheet
transaction.\38\ Finally, the Operational Page is part of the proposed
SSOI, and therefore would be subject to the same frequency and deadline
schedule of the proposed SSOI.
---------------------------------------------------------------------------
\38\ See SEA Rule 17a-25.
---------------------------------------------------------------------------
J. Implementation
Several commenters requested that FINRA provide sufficient lead
time for members to prepare for the new rule.\39\ A number of
commenters stated system changes would be needed to capture the
requested information.\40\ One commenter suggested that the
implementation of the proposed SSOI be staged as a series of pilots,
beginning with clearing firms, then gradually covering the membership
by firm size.\41\ FINRA is sensitive to the operational and systems
changes that may be necessary for members to complete the proposed
SSOI, and as a result, is proposing to implement the SSOI no sooner
than 180 days, and no later than 365 days, following Commission
approval of the proposed rule change.
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\39\ Citi, RBDA and SIFMA.
\40\ Citi, FAF, HCM, M.S. Howells, NAIBD, RBDA and SIFMA.
\41\ NAIBD.
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K. Alternatives to Schedule
A number of commenters offered alternatives to the proposed
SSOI.\42\ Several commenters suggested that more detailed information
should not be required unless the particular line item represents a
specified percentage of a firm's business or at least a dollar amount
threshold.\43\ One commenter suggested that FINRA consider requiring
that the information requested by the proposed SSOI be submitted
annually with the audit report.\44\ Another commenter believed that
instead of adopting the proposed SSOI, FINRA should meet with members
to discuss whether a new regulatory report is needed; what format works
best with the FOCUS Report; and consider the costs of implementing a
system.\45\ FINRA has considered these alternatives and believes that
obtaining information regarding the detail of revenues earned or
expenses incurred by product or other more specific categories is best
achieved through the proposed SSOI. FINRA notes that it consulted with
its advisory committees in connection with the development of the
proposed SSOI.
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\42\ Allegheny, NAIBD, Sutherland and Wachtel.
\43\ NAIBD, Sutherland and Wachtel.
\44\ Allegheny.
\45\ Sutherland.
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L. New Financial and Operational Reports or Schedules
Several commenters suggested that any new financial or operational
report or schedule required by FINRA be submitted to the SEC as a
proposed rule change to allow members an opportunity to provide FINRA
with feedback.\46\ One commenter suggested that such submission is
necessary due to possible conflicts that FINRA schedules and reports
may have with other laws and rules.\47\ Another commenter argued that
the opportunity for member comment is needed because specific line
items may be missing or irrelevant over time.\48\
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\46\ IMS, NAIBD, RBDA and Sutherland.
\47\ Sutherland.
\48\ NAIBD.
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As stated above, pursuant to proposed FINRA Rule 4524, FINRA will
file with the SEC the content of any Regulatory Notice (or similar
communication) issued pursuant to the proposed rule. Further, if such
content contains material substantive changes, FINRA will file the
content for comment with the SEC. Commenters will have an opportunity
to express their concerns and provide feedback at that time.
M. Comment Period
One commenter expressed disappointment that the comment period
ended the same day FINRA sent the Notice.\49\ The commenter believed
that FINRA did not give the public ample opportunity to study the
matter. FINRA believes the commenter is mistaken as the Notice was
issued on July 19, 2010, requesting comment until August 18, 2010.
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\49\ SCA.
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III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period (i) as the Commission may
designate up to 90 days of such date if it finds such longer period to
be appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A) By order approve or disapprove such proposed rule change, or
(B) institute proceedings to determine whether the proposed rule
change should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change 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 email to rule-comments@sec.gov. Please include
File Number SR-FINRA-2011-064 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-2011-064. This
file number should be included on the subject line if email 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
[[Page 70527]]
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-2011-064 and should be submitted on or before December 5,
2011.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\50\
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\50\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2011-29254 Filed 11-10-11; 8:45 am]
BILLING CODE 8011-01-P