Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of Partial Amendment No. 1 and Order Granting Accelerated Approval of a Proposed Rule Change Amending FINRA Rules 2210 (Communications With the Public), 2213 (Requirements for the Use of Bond Mutual Fund Volatility Ratings), and 2214 (Requirements for the Use of Investment Analysis Tools), as Modified by Partial Amendment No. 1, 64240-64247 [2016-22418]
Download as PDF
64240
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–78823; File No. SR–FINRA–
2016–018]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Partial Amendment No. 1 and Order
Granting Accelerated Approval of a
Proposed Rule Change Amending
FINRA Rules 2210 (Communications
With the Public), 2213 (Requirements
for the Use of Bond Mutual Fund
Volatility Ratings), and 2214
(Requirements for the Use of
Investment Analysis Tools), as
Modified by Partial Amendment No. 1
September 13, 2016.
I. Introduction
On May 25, 2016, Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Exchange
Act’’) 1 and Rule 19b–4 thereunder,2
proposed amendments that would
revise the filing requirements in FINRA
Rule 2210 (Communications with the
Public) and FINRA Rule 2214
(Requirements for the Use of Investment
Analysis Tools) and the content and
disclosure requirements in FINRA Rule
2213 (Requirements for the Use of Bond
Mutual Fund Volatility Ratings).
The proposed rule change was
published for comment in the Federal
Register on June 15, 2016.3 The public
comment period closed on July 6, 2016.
On July 19, 2016, FINRA extended the
time period in which the Commission
must approve the proposed rule change,
disapprove the proposed rule change, or
institute proceedings to determine
whether to approve or disapprove the
proposed rule change to September 13,
2016. The Commission received five
comment letters in response to the
Notice.4 On September 1, 2016, FINRA
responded to the comment letters
received in response to the Notice and
filed a partial amendment to the
mstockstill on DSK3G9T082PROD with NOTICES
1 15
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Exchange Act Release No. 78026 (June 9,
2016), 81 FR 39081 (June 15, 2016) (‘‘Notice’’).
4 See Letters from Hugh Berkson, Public Investors
Arbitration Bar Association, dated July 5, 2016
(‘‘PIABA Letter’’); Alexander C. Gavis, Fidelity
Investments, dated July 6, 2016 (‘‘Fidelity Letter’’);
Dorothy Donohue, Investment Company Institute,
dated July 6, 2016 (‘‘ICI Letter’’); Timothy W.
Cameron and Lindsey Weber Keljo, Securities
Industry and Financial Markets Association, dated
July 6, 2016 (‘‘SIFMA Letter’’); and Erica A. Green,
FOLIOfn Investments, Inc., dated July 7, 2016
(‘‘FOLIO Letter’’). Comment letters are available at
www.sec.gov.
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
proposed rule change (‘‘Partial
Amendment No. 1’’).5
This order provides notice of filing of
Partial Amendment No. 1 and approves
the proposal, as modified by Partial
Amendment No. 1, on an accelerated
basis.
II. Description of the Proposed Rule
Change
Background
In April 2014, FINRA launched a
retrospective review of its
communications with the public rules
to assess their effectiveness and
efficiency. In December 2014, FINRA
published a report on the assessment
phase of the review.6 The report
concluded that, while the rules have
met their intended investor protection
objectives, they could benefit from some
updating to better align the investor
protection benefits and the economic
impacts. To this end, FINRA
recommended consideration of a
combination of rule proposals, guidance
and administrative measures, to
enhance the efficiency of the rules with
no reduction in investor protection.
Pursuant to these recommendations,
FINRA initially is proposing
amendments to the filing requirements
in FINRA Rule 2210 and FINRA Rule
2214 and the content and disclosure
requirements in FINRA Rule 2213.
Original Proposal
New Member Communications
FINRA Rule 2210(c)(1)(A) currently
requires new FINRA members to file
with FINRA retail communications used
in any electronic or other public media
at least 10 business days prior to use.
This requirement extends for one year
from the effective date of the firm’s
membership. This new firm filing
requirement only applies to broadly
disseminated retail communications,
such as generally accessible Web sites,
print media communications, and
television and radio commercials.
In its initial proposal, FINRA stated
its belief that that the requirement for
new members to file their broadly
disseminated retail communications
serves a useful purpose, since new
5 See Letter from Joseph P. Savage, Vice President
and Counsel, Office of Regulatory Policy, FINRA, to
the Commission, dated September 1, 2016 (‘‘FINRA
Letter’’). The FINRA Letter and the text of Partial
Amendment No. 1 are 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; the text of the FINRA letter is also
available at the Commission’s Web site at https://
www.sec.gov/comments/sr-finra-2016-018/
finra2016018-6.pdf.
6 See Retrospective Rule Report, Communications
with the Public, December 2014.
PO 00000
Frm 00115
Fmt 4703
Sfmt 4703
members may not be as familiar with
the standards that apply to retail
communications as more established
members, but that the requirement to
file these communications at least 10
business days prior to use can delay
members’ abilities to communicate with
the public in a timely manner. For
example, if a new member wishes to
update its public Web site with new
information, the member must first file
the proposed update with FINRA and
wait at least 10 business days before it
can post this update on its Web site.
FINRA stated that such a delay may
hinder its ability to communicate
important information to its existing
and prospective customers.
FINRA stated that it believed it could
continue to protect investors from
potential harm without imposing this
time delay on new members by
reviewing new members’
communications on a post-use, rather
than a pre-use, basis. FINRA had found
a post-use filing requirement to be an
effective investor protection approach
for retail communications with similar
risk profiles as FINRA typically sees
from new members. Accordingly,
FINRA initially proposed to revise the
new member filing requirement to
require new members to file retail
communications used in electronic or
other public media within 10 business
days of first use for a one-year period,
rather than requiring these filings at
least 10 business days prior to use.7 As
explained in more detail below, upon
consideration of comments received on
the proposal, FINRA has determined not
to amend these requirements at this
time, and filed a Partial Amendment No.
1 with the Commission to that effect.8
Investment Company Shareholder
Reports
FINRA currently requires members to
file the management’s discussion of
fund performance (‘‘MDFP’’) portion of
a registered investment company
shareholder report if the report is
distributed or made available to
prospective investors.9 FINRA has
7 See proposed amendments to FINRA Rule
2210(c)(1)(A). This proposed change also would
delete as redundant current rule text that permits
a new member to file a retail communication that
is a free writing prospectus filed with the SEC
pursuant to Securities Act Rule 433(d)(1)(ii), within
10 business days of first use rather than at least 10
business days prior to first use.
8 See FINRA Letter at 3; see also Partial
Amendment No. 1.
9 See, e.g., Notice to Members 99–79 (September
1999) (‘‘[m]embers are not required to file
shareholder reports with [FINRA] if they are only
sent to current fund shareholders. However, if a
member uses a shareholder report as sales material
with prospective investors, the member must file
the management’s discussion of fund performance
E:\FR\FM\19SEN1.SGM
19SEN1
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
required the MDFP to be filed because
members sometimes distribute or make
shareholder reports available to
prospective investors to provide more
information about the funds they offer.
Thus, FINRA has considered the MDFP
to be subject to the filing requirement
for investment company retail
communications.
Although Rule 2210 does not contain
any express filing exclusion for
investment company shareholder
reports, FINRA has not required
members to file portions of shareholder
reports other than the MDFP, such as
the financial statements or schedules of
portfolio investments. FINRA has not
regarded these other parts of investment
company shareholder reports to be
subject to the filing requirements of
Rule 2210, since they serve a regulatory
purpose rather than promoting the sale
of investment company securities.
Investment companies already must
file shareholder reports with the SEC,10
and the MDFP typically presents less
investor risk than other types of
promotional communications
concerning investment companies, since
it usually focuses on the most recent
period covered by the report rather than
containing promotional content that is
intended to encourage future
investments. Accordingly, FINRA
proposes to exclude from the FINRA
filing requirements the MDFP by adding
an express exclusion for annual or semiannual reports that have been filed with
the SEC in compliance with applicable
requirements.11 FINRA believes that it
would assist members’ understanding of
Rule 2210 expressly to clarify that
annual and semi-annual reports that
have been filed with the SEC are not
subject to filing with FINRA. The rule
already excludes prospectuses, fund
profiles, offering circulars and similar
documents that have been filed with the
SEC. As such, FINRA believes it would
be consistent to add shareholder reports
that have been filed with the SEC to that
list.
mstockstill on DSK3G9T082PROD with NOTICES
Offering Documents Concerning
Unregistered Securities
Rule 2210(c)(7)(F) currently excludes
from filing ‘‘prospectuses, preliminary
prospectuses, fund profiles, offering
circulars and similar documents that
(MDFP) portion of the report (as well as any
supplemental sales material attached to or
distributed with the report) with the Department.’’).
10 See Section 30 of the Investment Company Act
of 1940 and Rules 30a–1 and 30b1–1 thereunder.
11 See proposed amendments to FINRA Rule
2210(c)(7)(F). To the extent that a member
distributes or attaches registered investment
company sales material along with the fund’s
shareholder report, such material would remain
subject to filing under Rule 2210.
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
have been filed with the SEC or any
state, or that is exempt from such
registration . . .’’ (emphasis supplied).
The filing exclusion is intended (and
has been interpreted by FINRA) to
exclude issuer-prepared offering
documents concerning securities
offerings that are exempt from
registration.
Accordingly, FINRA is proposing to
amend Rule 2210(c)(7)(F) to make this
intent more clear, and to avoid any
confusion concerning the phrase ‘‘or
that is exempt from such registration.’’
As revised, Rule 2210(c)(7)(F) would
exclude from filing, among other things,
‘‘similar offering documents concerning
securities offerings that are exempt from
SEC or state registration requirements.’’
While FINRA believes that this
amendment will clarify this filing
exclusion, it does not believe that it
represents a substantive change to the
current filing exclusion for unregistered
securities’ offering documents.
Backup Material for Investment
Company Performance Rankings and
Comparisons
A member that files a retail
communication for a registered
investment company that contains a
fund performance ranking or
performance comparison must include a
copy of the ranking or comparison used
in the retail communication.12 When
FINRA adopted this requirement, prior
to the Internet, FINRA staff did not have
ready access to the sources of rankings
or comparisons. Today, this information
typically is easily available online.
FINRA therefore proposes to eliminate
the requirement to file ranking and
comparison backup material and instead
expressly to require members to
maintain back-up materials as part of
their records.13
Generic Investment Company
Communications
FINRA Rule 2210(c)(3)(A) requires
members to file within 10 business days
of first use retail communications
‘‘concerning’’ registered investment
companies. FINRA proposes to revise
this filing requirement to cover only
retail communications that promote a
specific registered investment company
or family of registered investment
companies. Thus, members would no
longer be required to file generic
investment company retail
communications.
12 See
FINRA Rule 2210(c)(3)(A).
proposed amendments to FINRA Rules
2210(b)(4)(A)(vi) and 2210(c)(3)(A).
13 See
PO 00000
Frm 00116
Fmt 4703
Sfmt 4703
64241
An example of such a generic
communication would be a retail
communication that describes different
mutual fund types and features but does
not discuss the benefits of a specific
fund or fund family. This type of
material typically is intended to educate
the public about investment companies
in general or the types of products that
a member offers, and thus does not
present the same risks of including
potentially misleading information as
promotional communications about
specific funds or fund families.
Investment Analysis Tools
‘‘Investment analysis tools’’ are
interactive technological tools that
produce simulations and statistical
analyses that present the likelihood of
various investment outcomes if certain
investments are made or certain
investment strategies or styles are
undertaken. Pursuant to FINRA Rules
2210(c)(3)(C) and 2214(a), members that
intend to offer an investment analysis
tool must file templates for written
reports produced by, or retail
communications concerning, the tool,
within 10 business days of first use.
Rule 2214 also requires members to
provide FINRA with access to the tool
itself, and provide customers with
specific disclosures when members
communicate about the tool, use the
tool or provide written reports generated
by the tool.
Since Rule 2214 became effective in
2005,14 FINRA has found that members
have largely complied with the Rule’s
requirements applicable to templates for
written reports produced by investment
analysis tools and retail
communications concerning such tools.
FINRA does not believe that the filing
requirements for these templates and
retail communications are necessary
given this history and in light of the
investor protection afforded by other
content standards and the requirement
that members provide access to the tools
and their output upon request of FINRA
staff. Accordingly, FINRA proposes to
eliminate the filing requirements for
investment analysis tool report
templates and retail communications
concerning such tools and instead
require members to provide FINRA staff
with access to investment analysis tools
upon request.15
Filing Exclusion for Templates
Members are not required to file retail
communications that are based on
templates that were previously filed
14 See
Notice to Members 04–86 (November 2004).
proposed amendments to FINRA Rules
2210(c)(3) and 2214(a).
15 See
E:\FR\FM\19SEN1.SGM
19SEN1
64242
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
mstockstill on DSK3G9T082PROD with NOTICES
with FINRA but changed only to update
recent statistical or other non-narrative
information.16 However, members are
required to re-file previously filed retail
communications that are subject to
filing under FINRA Rule 2210(c) to the
extent that the member has updated any
narrative information contained in the
prior filing. Often these re-filed retail
communications are templates for fact
sheets concerning particular funds or
products and provide quarterly
information concerning a product’s
performance, portfolio holdings and
investment objectives.
Through its review of updated fund
fact sheets and other similar templates,
FINRA has found that certain narrative
information has not presented
significant risk to investors, and that
these narrative updates typically are
consistent with applicable standards. In
particular, narrative updates that are not
predictive in nature and merely describe
market events that occurred during the
period covered by the communication,
or that merely describe changes in a
fund’s portfolio, rarely have presented
significant investor risks. In addition,
members often will update narrative
information concerning a registered
investment company, such as a
description of a fund’s investment
objectives, based on information that is
sourced from the fund’s regulatory
documents filed with the SEC. In both
cases, FINRA believes that the costs
associated with filing these types of
narrative updates exceed the investor
benefits associated with FINRA staff
review of these updates.
Accordingly, FINRA proposes to
expand the template filing exclusion
also to allow members to include
updated non-predictive narrative
descriptions of market events during the
period covered by the communication
and factual descriptions of portfolio
changes without having to refile the
template, as well as updated
information that is sourced from a
registered investment company’s
regulatory documents filed with the
SEC.17
Bond Mutual Fund Volatility Ratings
FINRA Rule 2213 permits members to
use communications that include
ratings provided by independent third
parties that address the sensitivity of the
net asset value of an open-end
management investment company’s
bond portfolio to changes in market
conditions and the general economy,
subject to a number of requirements. For
16 See
FINRA Rule 2210(c)(7)(B).
proposed amendments to FINRA Rule
2210(c)(7)(B).
17 See
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
example, these communications must be
accompanied or preceded by the bond
fund’s prospectus and contain specific
disclosures. Members currently must
file retail communications that include
bond mutual fund volatility ratings at
least 10 business days prior to first use,
and withhold them from publication or
circulation until any changes specified
by FINRA have been made.18
FINRA believes that some of these
requirements have discouraged
members from including bond fund
volatility ratings in their
communications due to the significant
compliance burdens associated with
doing so, and the level of disclosures
required to accompany such ratings.
FINRA has found that, since Rule 2213
first became effective in 2000,19
members have rarely, if ever, filed
communications that contain bond fund
volatility ratings. In general, in the few
cases in which members filed such
communications with FINRA, the staff
has found that they have met applicable
standards.
Given that bond fund volatility ratings
may provide useful information to
investors, and that Rule 2213 as
currently drafted appears to have
discouraged members from including
these ratings in their communications,
FINRA believes it is appropriate to
revise the rule to reduce some of these
burdens while continuing to include
requirements that it believes will protect
investors. Accordingly, FINRA proposes
to modify some of Rule 2213’s
requirements.
Consistent with the filing
requirements for other retail
communications about specific
registered investment companies, the
proposal would no longer require a
retail communication that includes a
bond fund volatility rating to be
accompanied or preceded by a
prospectus for the fund, and would
permit members to file these
communications within 10 business
days of first use rather than prior to
use.20
FINRA believes that the requirement
that any retail communication including
a bond fund volatility rating be
accompanied or preceded by a fund
prospectus increases the burdens
associated with these communications
without adding commensurate investor
protection. Except in rare circumstances
due to operational hardship, all mutual
18 FINRA
Rules 2210(c)(2)(C) and 2213(b) and (c).
Notice to Members 00–23 (April 2000).
20 See proposed amendments to FINRA Rules
2210(c) and 2213(b). This change relates only to
Rule 2213 and does not affect a member’s obligation
to deliver a prospectus under the Securities Act or
for Investment Company Act companies.
19 See
PO 00000
Frm 00117
Fmt 4703
Sfmt 4703
fund prospectuses are available online,
and thus an investor can easily access
the prospectus, if needed.
Similarly, FINRA believes that
requiring members to file these retail
communications at least 10 business
days prior to use and to withhold them
from publication or circulation until any
changes specified by the Department
have been made does not provide
appreciably greater investor protection.
According to FINRA, this pre-use filing
requirement inhibits a member’s ability
to circulate retail communications
containing volatility ratings in a timely
manner. Moreover, members still would
be required to file these
communications within 10 business
days of first use, so that if they contain
misleading content, the Department staff
can take appropriate measures to correct
any problems, such as recommending
changes to the communication, or
directing the member to cease using the
communication with the public. FINRA
has found a post-use filing requirement
to be an effective investor protection
approach for most retail
communications with similar risk
profiles.21
The proposal also would streamline
the content and disclosure
requirements. In particular, the
amendments would eliminate the
requirements: (1) That all disclosures be
contained in a separate Disclosure
Statement; (2) to disclose all current
bond mutual fund volatility ratings that
have been issued with respect to the
fund; (3) to explain the reason for any
change in the current rating from the
most recent prior rating; (4) to describe
the criteria and methodologies used to
determine the rating; (5) to include a
statement that not all bond funds have
volatility ratings; and (6) to include a
statement that the portfolio may have
changed since the date of the rating.
FINRA believes that many of these
requirements are unnecessary in light of
the content requirements that still will
apply to such retail communications.
For example, members still would not
be permitted to refer to a volatility
rating as a ‘‘risk’’ rating, and would have
21 As a general matter, FINRA does not believe
that retail communications that include bond fund
volatility ratings present risks of investor harm that
are comparable to other retail communications that
require pre-use filing, such as retail
communications that include self-created rankings
or comparisons or retail communications
concerning security futures. See FINRA Rule
2210(c)(2)(A) and (B). Retail communications that
include self-created rankings or comparisons
present a greater risk of being misleading than bond
fund volatility ratings, since they are not created by
an entity that is independent of the member. In
addition, security futures are more complex and
potentially more volatile than most bond mutual
funds.
E:\FR\FM\19SEN1.SGM
19SEN1
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
to incorporate the most recently
available rating and reflect information
that, at a minimum, is current to the
most recent calendar quarter end. The
criteria and methodology used to
determine the rating still would have to
be based exclusively on objective,
quantifiable factors, and such
communications would have to include
a link to, or Web site address for, a Web
site that includes the criteria and
methodology. Communications would
have to provide the name of the entity
that issued the rating, the most current
rating and date for the rating, and
whether consideration was paid for the
rating, as well as a description of the
types of risks the rating measures.
FINRA believes that, as long as the
required disclosures are provided, it is
not necessary that they appear in a
separate Disclosure Statement. FINRA
also believes it is unnecessary to
disclose all other current volatility
ratings assigned to the advertised fund,
since this requirement is not imposed
under other similar rules. For example,
FINRA Rule 2214 allows members to
provide fund ranking information
without also requiring the member to
disclose all rankings assigned by other
ranking entities. The other disclosure
requirements add little understanding
about the rating presented, while adding
voluminous text to the retail
communication. In addition, if an
investor does seek more information
about the criteria and methodology used
to create the rating, this information will
be available via a hyperlink to a separate
Web site.
mstockstill on DSK3G9T082PROD with NOTICES
Proposed Partial Amendment No. 1
23 See
PIABA Letter at 2.
FINRA Letter at 3.
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
As noted above, the Commission
received five comment letters on the
proposed rule change 24 and a response
letter from FINRA.25 As discussed in
more detail below, four of the
commenters generally supported the
proposal, but had some suggestions for
changes.26 One commenter opposed the
proposal.27
Continuation of Retrospective Review
While two commenters generally
supported the proposal, both
encouraged FINRA to continue its
retrospective review of its rules
governing communications with the
public to address other areas.28 One
commenter recommended that FINRA
update its rules governing social media,
mobile devices, and electronic
communications, to address the amount
of disclosure FINRA requires in print
advertising, and to eliminate to the
extent possible differences among the
rules governing broker-dealer and
investment adviser communications,
particularly with respect to
communications containing projections
or performance information.29 Another
commenter recommended that FINRA
codify a set of clear disclosure standards
for closed-end fund marketing materials
and to eliminate the filing requirement
for these communications.30
In its response, FINRA stated that it
continues to consider additional action
on its retrospective review of the
communications rules, including those
raised by commenters on this
proposal.31
New Member Filing Requirements
In response to comments 22 (discussed
below), FINRA has determined not to
amend its current new member filing
requirements, as set forth in FINRA Rule
2210(c)(1)(A), at this time. It has
therefore deleted the proposed changes
to FINRA Rule 2210(c)(1)(A). Although
FINRA believes that it is a close balance
between the investor protection benefits
provided by pre-use review and the
burden of complying with the existing
rule, FINRA believes that it is more
prudent to defer making the change to
post-use filing of new member retail
communications at this time. FINRA
will continue to accumulate more data
on the frequency and types of revisions
required for new member retail
communications before determining
whether to consider any changes to this
requirement in the future.23
22 See
III. Comment Summary and FINRA’s
Response
FINRA Rule 2210(c)(1)(A) currently
requires new FINRA members to file
with FINRA retail communications used
in any electronic or other public media
at least 10 business days prior to use.
This requirement extends for one year
from the effective date of the firm’s
membership. This new firm filing
requirement only applies to broadly
disseminated retail communications,
such as generally accessible Web sites,
print media communications, and
television and radio commercials. The
initial proposal would have modified
this requirement to permit new
24 See
supra note 4.
supra note 5.
26 See Fidelity Letter, FOLIO Letter, ICI Letter,
and SIFMA Letter.
27 See PIABA Letter.
28 See Fidelity Letter and ICI Letter.
29 See Fidelity Letter.
30 See ICI Letter.
31 See FINRA Letter at 2.
25 See
PO 00000
Frm 00118
Fmt 4703
Sfmt 4703
64243
members to file these retail
communications within 10 business
days of first use for a one-year period,
rather than requiring these filings at
least 10 business days prior to use.32
One commenter strongly opposed the
proposed change to the new member
filing requirement.33 The commenter
stated that the proposed change would
eliminate the proactive investor
protection that the current rule affords
customers, and that post-use review of
all new member retail communications
by FINRA will not provide adequate
investor protection for customers.34 The
commenter also argued that the pre-use
filing requirement provides a deterrent
effect to potential bad actors, and that a
post-use filing requirement would
embolden new members to prepare
riskier retail communications.35
Another commenter supported the
proposed change to the new member
filing requirement from a pre-use to a
post-use requirement, but argued that
FINRA should go further and eliminate
the filing requirement entirely in some
circumstances.36 This commenter
asserted that other rules and
requirements currently in place are
sufficient to offer the important investor
protections contemplated by the new
member filing requirement, citing as an
example FINRA’s new member
application process pursuant to NASD
Rule 1013.37 The commenter suggested
that FINRA impose the filing
requirement only on new members that
do not have compliance or supervisory
personnel with at least five years of
experience directly related to sales
practice requirements that would be
responsible for reviewing and approving
the firm’s retail communications.38
Alternatively, the commenter suggested
narrowing the new member filing
requirement to exclude generic retail
communications and retail
32 The proposed change also would delete as
redundant current rule text that permits a new
member to file a retail communication that is a free
writing prospectus filed with the SEC pursuant to
Securities Act Rule 433(d)(1)(ii) within 10 business
days of first use rather than at least 10 business
days prior to first use.
33 See PIABA Letter at 1–3.
34 See id. at 2–3.
35 See PIABA Letter at 2–3. As FINRA stated in
its response, ‘‘PIABA also criticized the proposed
changes to the new member filing requirement
based on the apparently mistaken belief that the
proposal would differentiate its application
between new member Web sites, and other widely
disseminated retail communications.’’ See FINRA
Letter at 3 n.5. FINRA therefore clarified that
‘‘although an earlier version of the proposal
contained such a distinction, the version FINRA
filed with the Commission for comment did not.’’
Id.
36 See FOLIO Letter at 1–2.
37 See id.
38 See id.
E:\FR\FM\19SEN1.SGM
19SEN1
64244
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
communications that contain nonpredictive narrative descriptions.39
In response to the suggestion by one
commenter that FINRA eliminate the
new member filing requirement in
certain circumstances and narrow it in
others, FINRA noted that the current
rule already contains a mechanism to
provide regulatory relief in the kinds of
circumstances the commenter cited.40
FINRA stated in its response that it is
authorized conditionally or
unconditionally to grant an exemption
from the new member filing
requirement for good cause shown.41
Thus, if a member makes a persuasive
case that the new member filing
requirement should not apply to the
firm, such as where the new firm is the
successor to an existing firm and its
compliance personnel have
demonstrated familiarity with the
communications rules, FINRA may
consider granting an exemption from
the filing requirement.42 In addition,
FINRA noted that even new members
are not required to file retail
communications where those
communications do not make a
financial or investment
recommendation or otherwise promote a
product or service of the member.43
Thus, FINRA’s view is that truly
generic, non-promotional retail
communications need not be filed under
this requirement.44
After considering all of the comments,
FINRA stated that it has determined not
to amend its current new member filing
requirements at this time.45 Although
FINRA believes that it is a close balance
between the investor protection benefits
provided by pre-use review and the
burden of complying with the existing
rule, FINRA believes that it is more
prudent to defer making the change to
post-use filing of new member retail
communications at this time.46 FINRA
stated that it will continue to
accumulate more data on the frequency
and types of revisions required for new
member retail communications before
determining whether to consider any
changes to this requirement in the
future.47
mstockstill on DSK3G9T082PROD with NOTICES
Investment Company Shareholder
Reports
FINRA currently requires members to
file the management’s discussion of
39 See
id.
FINRA Letter at 3.
41 See FINRA Rule 2210(c)(9)(A).
42 See FINRA Letter at 3.
43 See id.; see also FINRA Rule 2210(c)(7)(C).
44 See FINRA Letter at 3.
45 See FINRA Letter at 3.
46 See id.
47 See id.
fund performance (‘‘MDFP’’) portion of
a registered investment company
shareholder report if the report is
distributed or made available to
prospective investors. FINRA proposes
to exclude from the FINRA filing
requirements the MDFP by adding an
express exclusion for annual or semiannual reports that have been filed with
the SEC in compliance with applicable
requirements.
Two commenters supported this
proposed change.48 One commenter
noted that this exclusion would make
FINRA’s rule less burdensome on asset
management firms by eliminating
redundant filing requirements.49
Another commenter opposed this
change on the ground that Commission
staff does not fully review all regulatory
filings made on the EDGAR system,
which is where filings of fund
shareholder reports are made.50
In its response, FINRA stated that it
maintains that the MDFP portion of
shareholder reports should be excluded
from the filing requirements.51 FINRA
stated that it has found through its filing
program that the MDFPs in shareholder
reports rarely have raised issues
requiring members to revise or
withdraw reports from circulation.52
FINRA acknowledged that Commission
staff may not review all securitiesrelated filings contemporaneous with
their submission, but pointed out in its
response that Commission staff can
review higher risk communications as
needed.53 FINRA stated its belief that
this change would not appreciably
impact investor protection and would
allow FINRA to allocate its staff
resources more efficiently to focus on
reviewing higher risk communications
more expeditiously.54
Generic Investment Company
Communications
FINRA Rule 2210(c)(3)(A) requires
members to file within 10 business days
of first use retail communications
‘‘concerning’’ registered investment
companies. FINRA proposes to revise
this filing requirement to cover only
retail communications that promote a
specific registered investment company
or family of registered investment
companies. Thus, members would no
longer be required to file generic
investment company retail
communications.
40 See
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
Two commenters supported this
proposed change.55 However, one
commenter requested that FINRA clarify
how this filing exclusion interrelates
with Securities Act Rule 482.56 In
response to this request, FINRA stated
in its response that it intends the
registered investment company filing
requirement to apply to any retail
communication that is governed by
either Securities Act Rule 482 or
Investment Company Act Rule 34b–1, or
that otherwise promotes or recommends
a specific registered investment
company or family of registered
investment companies.57 To the extent
that a retail communication qualifies as
a generic investment company
advertisement under Securities Act Rule
135a, FINRA stated that a member
would not be required to file the retail
communication.58
Filing Exclusion for Templates
Under current rules, members are not
required to file retail communications
that are based on templates that were
previously filed with FINRA but
changed only to update recent statistical
or other non-narrative information.59
However, members are required to refile previously filed retail
communications that are subject to
filing under FINRA Rule 2210(c) to the
extent that the member has updated
narrative information contained in the
prior filing.
FINRA’s proposal would expand the
template filing exclusion also to allow
members to include updated, nonpredictive narrative descriptions of
market events that occurred during the
period covered by the communication
and factual descriptions of portfolio
changes without having to re-file the
template. Similarly, a template could
include information that is sourced from
a registered investment company’s
regulatory documents filed with the
Commission without triggering a
requirement to re-file.
Two commenters supported this
proposed change, but recommended
amending the proposal.60 One of these
commenters recommended that the
exclusion cover any non-predictive
narrative information that comes from
either an independent data provider or
is sourced from an investment
company’s regulatory documents filed
55 See
48 See
FINRA Letter at 4.
49 See SIFMA Letter at 2.
50 See PIABA Letter at 4.
51 See FINRA Letter at 4.
52 See id.
53 See id.
54 See id.
PO 00000
Frm 00119
Fmt 4703
FOLIO Letter at 3; see also SIFMA Letter
at 3.
56 See
SIFMA Letter at 3.
FINRA Letter at 4–5.
58 See FINRA Letter at 5.
59 See FINRA Rule 2210(c)(7)(B).
60 See Fidelity Letter at 2–3; see also ICI Letter at
3–4.
57 See
Sfmt 4703
E:\FR\FM\19SEN1.SGM
19SEN1
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
with the Commission.61 This
commenter recommended that, at the
very least, this filing exclusion cover
non-predictive narrative information
that is (1) purchased or licensed directly
from a third-party data provider, and (2)
sourced from a Commission
document.62
The second commenter recommended
that the filing exclusion cover
modifications limited to narrative
factual changes provided by any
‘‘ranking entity,’’ as such term is
defined in FINRA Rule 2212(a).63 The
commenter also recommended that
FINRA broaden the reference to ‘‘nonpredictive narrative information that
describes market events’’ to expressly
permit commentary.64 Finally, the
commenter argued that otherwise the
proposal could be unduly narrow and
difficult for members to apply.65
One commenter opposed this change
entirely, arguing that FINRA should
review any narrative descriptions
included in retail communications for
misleading information.66 The
commenter cited several recent FINRA
enforcement cases involving misleading
retail communications as grounds for
maintaining FINRA’s current template
filing exclusion.67
In its response, FINRA disagreed that
Rule 2210 should exclude from filing
any template updates that are based on
any non-predictive narrative
information that is sourced from an
independent data provider.68 FINRA
stated its belief that such a standard
could potentially permit inclusion of
non-predictive narrative information
that is intended to promote future sales
of a fund, which FINRA believes should
be re-filed.69 However, FINRA stated if
a member updates a template based on
information that is sourced from a
registered investment company’s
regulatory documents filed with the
Commission, the update would qualify
for this filing exclusion.70 FINRA stated
that this exclusion would apply even if
an independent data provider supplies
the information that is sourced from the
Commission filings.71
Further, FINRA stated that it does not
agree that the template filing exclusion
should be based on whether narrative
factual changes are provided by a
ranking entity as defined in Rule 2212.72
FINRA stated its belief that the better
test is whether the information is
sourced from Commission filings, rather
than basing it on the provider’s business
model.73
FINRA stated that it does not agree
that the template filing exclusion also
should cover commentary.74 As one
commenter acknowledged, commentary
often includes forward looking
statements about the market or a
particular fund.75 Accordingly, FINRA
believes these kinds of narrative updates
should be re-filed.76
Finally, FINRA stated that it does not
believe the enforcement cases cited by
one commenter support its opposition
to revising the template filing
exclusion.77 Those cases did not involve
updates of templates, but rather instead
involved misleading marketing
materials that members would continue
to be required to file even after the
proposed change to the template filing
exclusion.78 FINRA noted that its
members are already required to file
mutual fund retail communications, and
to the extent a member is using a retail
communication that becomes
misleading due to changes in market
conditions, the member must either
cease using the communication or revise
the communication to make it
accurate.79 If the revision constitutes a
material change to the retail
communication, the member must refile it.80
Moreover, FINRA noted, the FINRA
Rule 2210 content standards apply
regardless of whether a member re-files
a retail communication with FINRA.81
FINRA believes existing standards, even
after this change to the template filing
exclusion, strongly protect retail
investors from receiving potentially
misleading communications.82
Accordingly, FINRA stated that it is not
revising its proposed changes to the
template filing exclusion.83
Bond Fund Volatility Ratings
FINRA Rule 2213 permits members to
use communications that include
ratings provided by independent third
parties that address the sensitivity of the
net asset value of a bond mutual fund’s
72 See
id.
73 See id.
74 See id.
75 See ICI Letter at 4 n.10.
76 See FINRA Letter at 6.
77 See FINRA Letter at 6.
78 See id.
79 See id.
80 See FINRA Rule 2210(c)(7)(A).
81 See FINRA Letter at 6.
82 See id.
83 See id.
61 See
Fidelity Letter at 2–3.
id. at 2.
63 See ICI Letter at 3.
64 See id. at 4.
65 See id.
66 See PIABA Letter at 4–5.
67 See id.
68 See FINRA Letter at 6.
69 See id.
70 See id.
71 See id.
mstockstill on DSK3G9T082PROD with NOTICES
62 See
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
PO 00000
Frm 00120
Fmt 4703
Sfmt 4703
64245
portfolio to changes in market
conditions and the general economy,
subject to a number of requirements.
These requirements include that the
communication be accompanied or
preceded by the fund’s prospectus, that
it be filed at least 10 business days prior
to use with FINRA, and that it include
a number of disclosures. FINRA has
proposed to revise these requirements
by no longer requiring such
communications to be accompanied or
preceded by a fund prospectus, by
allowing members to file such
communications within 10 business
days of first use rather than 10 days
prior to use, and by streamlining some
of the content standards and required
disclosures.
One commenter opposed these
changes on the ground that recent
enforcement actions involving the sale
of bond funds demonstrate that bond
funds should be highly regulated.84
FINRA responded that although it
agrees that bond funds and members’
sales of such funds should be effectively
regulated, it disagrees that the proposed
changes would undermine this goal.85
FINRA noted that the commenter did
not allege that any of its cited cases
involved communications that included
bond fund volatility ratings, and
additionally pointed out that FINRA has
not brought any enforcement actions
involving violations of FINRA Rule
2213.86
In addition, FINRA stated that the
proposed changes would not alter a
FINRA member’s obligation to file retail
communications concerning bond
mutual funds.87 FINRA stated that the
only filing change would be that retail
communications that included a bond
fund volatility rating would have to be
filed within 10 business days of first
use, similar to any other retail
communication concerning a specific
fund or fund family, rather than at least
10 business days prior to use.88 Finally,
FINRA stated that Rule 2213 also would
continue to impose content and
disclosure requirements that will
provide investors with significant
information about the meaning and
limitations of volatility ratings.89
IV. Discussion and Commission
Findings
After careful review of the proposed
rule change, as modified by Partial
Amendment No. 1, the comment letters,
84 See
PIABA Letter at 5–6.
FINRA Letter at 7.
86 See FINRA Letter at 7.
87 See id.
88 See id.
89 See id.
85 See
E:\FR\FM\19SEN1.SGM
19SEN1
64246
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
mstockstill on DSK3G9T082PROD with NOTICES
and FINRA’s response to the comments,
the Commission finds that the proposal,
as modified by Partial Amendment No.
1, is consistent with the requirements of
the Exchange Act and the rules and
regulations thereunder that are
applicable to a national securities
association.90 Specifically, the
Commission finds that the rule change
is consistent with Section 15A(b)(6) of
the Exchange Act,91 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.
As stated in the Notice, FINRA
believes that the proposal will ‘‘enhance
the efficiency’’ of its communications
with the public rules ‘‘with no
reduction in investor protection.’’ 92
Specifically, FINRA ‘‘believes that the
proposed rule change will improve
efficiency and reduce regulatory burden
by reducing the filing requirements
applicable to retail communications
distributed by members and
streamlining the content and disclosure
requirements for retail communications
that include bond mutual fund volatility
ratings, while maintaining necessary
investor protections.’’ 93 With respect to
the proposal for amending the new
member filing requirements in FINRA
Rule 2210(c)(1)(A), FINRA stated in its
response upon consideration of the
comments that were filed in opposition
to the proposal, that ‘‘it is more prudent
to defer making the change to post-use
filing of new member retail
communications at this time.’’ 94 It
therefore filed Partial Amendment No. 1
on September 1, 2016, in which it
proposed that the new member pre-use
filing requirements in FINRA Rule
2210(c)(1)(A) remain unchanged.95
Taking into consideration the
comments and FINRA’s response and
proposed partial amendment, the
Commission believes that the proposal
is consistent with the Exchange Act.
The Commission believes that the
proposal promotes regulatory efficiency
by selectively streamlining content and
disclosure requirements for retail
communications without undermining
strong regulatory protections for
investors.
90 In approving this rule change, the Commission
has considered the rule’s impact on efficiency,
competition, and capital formation. See 15 U.S.C.
78c(f).
91 15 U.S.C. 78o–3(b)(6).
92 Notice at 39081.
93 Notice at 39084.
94 FINRA Letter at 3.
95 Partial Amendment No. 1.
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
The Commission further believes that
FINRA’s response, as discussed in more
detail above, appropriately addressed
commenters’ concerns and adequately
explained its reasons for modifying its
proposal to maintain the current pre-use
filing requirement for new member
retail communications. The Commission
believes that this modification responds
to one of the primary concerns raised by
the commenter opposing the proposal
on the grounds that changing to a postuse filing requirement for new members
would not provide adequate investor
protection, and that a pre-use filing
requirement has a deterrent effect on
bad actors.96 As noted above, FINRA
plans to continue to ‘‘accumulate more
data on the frequency and types of
revisions required for new member
retail communications before
determining whether to consider any
changes to this requirement in the
future.’’ 97 The Commission believes
that the approach proposed by FINRA is
appropriate and designed to protect
investors and the public interest,
consistent with Section 15A(b)(6) of the
Exchange Act. For these reasons, the
Commission finds that the proposed
rule change is consistent with the
Exchange Act and the rules and
regulations thereunder.
V. Solicitation of Comments on Partial
Amendment No. 1 to the Proposed Rule
Change
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposal, as
modified by Partial Amendment No. 1,
is consistent with the Exchange 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–2016–018 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–FINRA–2016–018. 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 20549–1090, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing will also 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–
2016–018 and should be submitted on
or before October 11, 2016.
VI. Accelerated Approval of Proposed
Rule Change, as Modified by Partial
Amendment No. 1
The Commission finds good cause to
approve the proposed rule change, as
modified by Partial Amendment No. 1,
prior to the thirtieth day after the date
of publication of notice of the amended
proposal in the Federal Register. The
revisions made to the proposal in Partial
Amendment No. 1 will provide that the
current pre-use filing requirement for
new member retail communications
remains unchanged, as currently set
forth in FINRA Rule 2210(c)(1)(A). As
noted above, the Commission believes
that this modification responds to one of
the primary concerns raised by the
commenter opposing the proposal on
the grounds that changing to a post-use
filing requirement for new members
would not provide adequate investor
protection,98 and notes that FINRA
plans to continue to accumulate more
data before determining whether to
consider any changes to this
requirement in the future.99
Accordingly, the Commission finds
good cause, pursuant to Section 19(b)(2)
of the Exchange Act,100 to approve the
proposed rule change, as modified by
98 See
96 See
PIABA Letter at 2–3.
97 FINRA Letter at 3.
PO 00000
Frm 00121
Fmt 4703
Sfmt 4703
PIABA Letter at 2–3.
FINRA Letter at 3.
100 15 U.S.C. 78s(b)(2).
99 See
E:\FR\FM\19SEN1.SGM
19SEN1
Federal Register / Vol. 81, No. 181 / Monday, September 19, 2016 / Notices
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
Partial Amendment No. 1, on an
accelerated basis.
VII. Conclusion
It is therefore ordered pursuant to
Section 19(b)(2) 101 of the Exchange Act
that the proposal (SR–FINRA–2016–
018), as modified by Partial 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.102
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–22418 Filed 9–16–16; 8:45 am]
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
1. Purpose
[Release No. 34–78831; File No. SR–
NYSEARCA–2016–126]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Extend the Deadline
for Implementing Rule 6.61(a)(2) and
(3) Until September 30, 2016
September 13, 2016.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that, on
September 6, 2016, NYSE Arca, Inc. (the
‘‘Exchange’’ or ‘‘NYSE Arca’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
mstockstill on DSK3G9T082PROD with NOTICES
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to extend the
deadline for implementing Rule
6.61(a)(2) and (3) until September 30,
2016. The proposed rule change is
available on the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
101 Id.
102 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
1 15
VerDate Sep<11>2014
21:47 Sep 16, 2016
Jkt 238001
In its filing with the Commission, the
self-regulatory organization 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 those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
The Exchange is proposing to extend
the deadline for implementing Rule 6.61
(a)(2) and (3) until September 30, 2016.
The Exchange has not met the current
implementation deadline of July 31,
2016.
In March 2015, the Commission
approved Rule 6.61, which provides a
price protection risk mechanism for
Market Maker quotes.4 Rule 6.61
provides two layers of price protection
to incoming Market Maker quotes,
rejecting those Market Maker quotes that
exceed certain parameters, as a risk
mitigation tool.5 The Exchange has
implemented the first layer of price
protection (the NBBO Reasonability
Check) and had until one year from the
date of the Approval Order to
implement the second layer of
protection (the Underlying Stock Price/
Strike Price Check) pursuant to
4 See Securities Exchange Act Release No. 74441
(March 4, 2015), 80 FR 12664 (March 10, 2015) (SR–
NYSEArca–2014–150) (Approval Order); see also
Securities Exchange Act Release No. 74018 (January
8, 2015), 80 FR 1982 (January 14, 2015) (SR–
NYSEArca–2014–150) (Notice).
5 The first layer of price protection assesses
incoming sell quotes against the NBB and incoming
buy quotes against the NBO (the ‘‘NBBO Price
Reasonability Check’’). Specifically, Rule 6.61(a)(1)
provided that when an NBBO is available, a Market
Maker quote would be rejected if it is priced a
specified dollar amount or percentage through the
contra-side NBBO. The second layer of price
protection assesses the price of call or put bids
against a specified benchmark (the ‘‘Underlying
Stock Price/Strike Price Check’’), per Rule 6.61(a)(2)
and (3). This second layer of protection applies to
bids in call options or put options when (1) there
is no NBBO available, for example, during preopening or prior to conducting a re-opening after a
trading halt, or (2) if the NBBO is so wide as to not
reflect an appropriate price for the respective
options series.
PO 00000
Frm 00122
Fmt 4703
Sfmt 4703
64247
Commentary .01 to Rule 6.61, which
was March 4, 2016.6
In March 2016, because the Exchange
had not yet implemented the
Underlying Stock Price/Strike Price
Check, the Exchange extended the
deadline to implement Rule 6.61(a)(2)
and (3) until July 31, 2016 (the ‘‘July
31st Deadline’’).7 Subsequent to this
extension, the Exchange modified
Commentary .01 to Rule 6.61 to exclude
from the Underlying Stock Price/Strike
Price Check certain securities for which
there was no reliable (or in some cases
any) last sale data.8 Although the
Exchange had finalized the technology
related to the Underlying Stock Price/
Strike Price Check, because this
technology was packaged in a larger
technology release that is currently
being rolled out, the Exchange was not
able to implement the technology by the
July 31st Deadline. The Exchange is in
the process of implementing the
technology release that includes the
Underlying Stock Price/Strike Price
Check and plans to complete this
implementation no later than the end of
September 2016. The Exchange believes
the proposed extension of the July 31st
Deadline until September 30, 2016
would provide the Exchange with
sufficient time to implement the
functionality related to the rule.
Moreover, the proposed change would
update the rule to reflect the extended
deadline, thus making clear to investors
and the public that the Underlying
Stock Price/Strike Price Check is not yet
implemented.9
2. Statutory Basis
The proposed rule change is
consistent with Section 6(b) of the
6 See Securities Exchange Act Release No. 75156
(June 11, 2015), 80 FR 34756 (June 17, 2015) (SR–
NYSEArca–2015–45).
7 See Securities Exchange Act Release No. 77357
(March 14, 2016), 81 FR 14912 (March 18, 2016)
(SR–NYSEARCA–2016–41).
8 See Securities Exchange Act Release No. 77748
(April 29, 2016), 81 FR 27178 (May 5, 2016) (SR–
NYSEARCA–2016–57).
9 The Exchange has issued Trader Updates
informing its market participants that the
functionality related to the Underlying Stock Price/
Strike Price Check is not yet available but is
currently being implemented (together with the
other technology updates with which it was
packaged). See, e.g., Trader Updates regarding
Enhancements to Risk Control Functionality in
Enhanced Certification Environment, dated 6/6/16,
available here, https://www.nyse.com/publicdocs/
nyse/notifications/trader-update/NYSE%20
Amex%20and%20Arca%20%20Enhanced%20Risk%
20Controls%20in%20Enhanced%20Cert.pdf and
regarding Risk Controls/Series Lookup Table
Enhancements, dated 8/4/16, available here,
https://www.nyse.com/publicdocs/nyse/
notifications/trader-update/
NYSE%20Arca%20Options%20%20Risk%20Controls%20Release.pdf.
E:\FR\FM\19SEN1.SGM
19SEN1
Agencies
[Federal Register Volume 81, Number 181 (Monday, September 19, 2016)]
[Notices]
[Pages 64240-64247]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-22418]
[[Page 64240]]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-78823; File No. SR-FINRA-2016-018]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of Partial Amendment No. 1 and Order
Granting Accelerated Approval of a Proposed Rule Change Amending FINRA
Rules 2210 (Communications With the Public), 2213 (Requirements for the
Use of Bond Mutual Fund Volatility Ratings), and 2214 (Requirements for
the Use of Investment Analysis Tools), as Modified by Partial Amendment
No. 1
September 13, 2016.
I. Introduction
On May 25, 2016, Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Exchange Act'') \1\ and Rule 19b-4
thereunder,\2\ proposed amendments that would revise the filing
requirements in FINRA Rule 2210 (Communications with the Public) and
FINRA Rule 2214 (Requirements for the Use of Investment Analysis Tools)
and the content and disclosure requirements in FINRA Rule 2213
(Requirements for the Use of Bond Mutual Fund Volatility Ratings).
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
The proposed rule change was published for comment in the Federal
Register on June 15, 2016.\3\ The public comment period closed on July
6, 2016. On July 19, 2016, FINRA extended the time period in which the
Commission must approve the proposed rule change, disapprove the
proposed rule change, or institute proceedings to determine whether to
approve or disapprove the proposed rule change to September 13, 2016.
The Commission received five comment letters in response to the
Notice.\4\ On September 1, 2016, FINRA responded to the comment letters
received in response to the Notice and filed a partial amendment to the
proposed rule change (``Partial Amendment No. 1'').\5\
---------------------------------------------------------------------------
\3\ See Exchange Act Release No. 78026 (June 9, 2016), 81 FR
39081 (June 15, 2016) (``Notice'').
\4\ See Letters from Hugh Berkson, Public Investors Arbitration
Bar Association, dated July 5, 2016 (``PIABA Letter''); Alexander C.
Gavis, Fidelity Investments, dated July 6, 2016 (``Fidelity
Letter''); Dorothy Donohue, Investment Company Institute, dated July
6, 2016 (``ICI Letter''); Timothy W. Cameron and Lindsey Weber
Keljo, Securities Industry and Financial Markets Association, dated
July 6, 2016 (``SIFMA Letter''); and Erica A. Green, FOLIOfn
Investments, Inc., dated July 7, 2016 (``FOLIO Letter''). Comment
letters are available at www.sec.gov.
\5\ See Letter from Joseph P. Savage, Vice President and
Counsel, Office of Regulatory Policy, FINRA, to the Commission,
dated September 1, 2016 (``FINRA Letter''). The FINRA Letter and the
text of Partial Amendment No. 1 are 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; the text of the FINRA letter is
also available at the Commission's Web site at https://www.sec.gov/comments/sr-finra-2016-018/finra2016018-6.pdf.
---------------------------------------------------------------------------
This order provides notice of filing of Partial Amendment No. 1 and
approves the proposal, as modified by Partial Amendment No. 1, on an
accelerated basis.
II. Description of the Proposed Rule Change
Background
In April 2014, FINRA launched a retrospective review of its
communications with the public rules to assess their effectiveness and
efficiency. In December 2014, FINRA published a report on the
assessment phase of the review.\6\ The report concluded that, while the
rules have met their intended investor protection objectives, they
could benefit from some updating to better align the investor
protection benefits and the economic impacts. To this end, FINRA
recommended consideration of a combination of rule proposals, guidance
and administrative measures, to enhance the efficiency of the rules
with no reduction in investor protection.
---------------------------------------------------------------------------
\6\ See Retrospective Rule Report, Communications with the
Public, December 2014.
---------------------------------------------------------------------------
Pursuant to these recommendations, FINRA initially is proposing
amendments to the filing requirements in FINRA Rule 2210 and FINRA Rule
2214 and the content and disclosure requirements in FINRA Rule 2213.
Original Proposal
New Member Communications
FINRA Rule 2210(c)(1)(A) currently requires new FINRA members to
file with FINRA retail communications used in any electronic or other
public media at least 10 business days prior to use. This requirement
extends for one year from the effective date of the firm's membership.
This new firm filing requirement only applies to broadly disseminated
retail communications, such as generally accessible Web sites, print
media communications, and television and radio commercials.
In its initial proposal, FINRA stated its belief that that the
requirement for new members to file their broadly disseminated retail
communications serves a useful purpose, since new members may not be as
familiar with the standards that apply to retail communications as more
established members, but that the requirement to file these
communications at least 10 business days prior to use can delay
members' abilities to communicate with the public in a timely manner.
For example, if a new member wishes to update its public Web site with
new information, the member must first file the proposed update with
FINRA and wait at least 10 business days before it can post this update
on its Web site. FINRA stated that such a delay may hinder its ability
to communicate important information to its existing and prospective
customers.
FINRA stated that it believed it could continue to protect
investors from potential harm without imposing this time delay on new
members by reviewing new members' communications on a post-use, rather
than a pre-use, basis. FINRA had found a post-use filing requirement to
be an effective investor protection approach for retail communications
with similar risk profiles as FINRA typically sees from new members.
Accordingly, FINRA initially proposed to revise the new member filing
requirement to require new members to file retail communications used
in electronic or other public media within 10 business days of first
use for a one-year period, rather than requiring these filings at least
10 business days prior to use.\7\ As explained in more detail below,
upon consideration of comments received on the proposal, FINRA has
determined not to amend these requirements at this time, and filed a
Partial Amendment No. 1 with the Commission to that effect.\8\
---------------------------------------------------------------------------
\7\ See proposed amendments to FINRA Rule 2210(c)(1)(A). This
proposed change also would delete as redundant current rule text
that permits a new member to file a retail communication that is a
free writing prospectus filed with the SEC pursuant to Securities
Act Rule 433(d)(1)(ii), within 10 business days of first use rather
than at least 10 business days prior to first use.
\8\ See FINRA Letter at 3; see also Partial Amendment No. 1.
---------------------------------------------------------------------------
Investment Company Shareholder Reports
FINRA currently requires members to file the management's
discussion of fund performance (``MDFP'') portion of a registered
investment company shareholder report if the report is distributed or
made available to prospective investors.\9\ FINRA has
[[Page 64241]]
required the MDFP to be filed because members sometimes distribute or
make shareholder reports available to prospective investors to provide
more information about the funds they offer. Thus, FINRA has considered
the MDFP to be subject to the filing requirement for investment company
retail communications.
---------------------------------------------------------------------------
\9\ See, e.g., Notice to Members 99-79 (September 1999)
(``[m]embers are not required to file shareholder reports with
[FINRA] if they are only sent to current fund shareholders. However,
if a member uses a shareholder report as sales material with
prospective investors, the member must file the management's
discussion of fund performance (MDFP) portion of the report (as well
as any supplemental sales material attached to or distributed with
the report) with the Department.'').
---------------------------------------------------------------------------
Although Rule 2210 does not contain any express filing exclusion
for investment company shareholder reports, FINRA has not required
members to file portions of shareholder reports other than the MDFP,
such as the financial statements or schedules of portfolio investments.
FINRA has not regarded these other parts of investment company
shareholder reports to be subject to the filing requirements of Rule
2210, since they serve a regulatory purpose rather than promoting the
sale of investment company securities.
Investment companies already must file shareholder reports with the
SEC,\10\ and the MDFP typically presents less investor risk than other
types of promotional communications concerning investment companies,
since it usually focuses on the most recent period covered by the
report rather than containing promotional content that is intended to
encourage future investments. Accordingly, FINRA proposes to exclude
from the FINRA filing requirements the MDFP by adding an express
exclusion for annual or semi-annual reports that have been filed with
the SEC in compliance with applicable requirements.\11\ FINRA believes
that it would assist members' understanding of Rule 2210 expressly to
clarify that annual and semi-annual reports that have been filed with
the SEC are not subject to filing with FINRA. The rule already excludes
prospectuses, fund profiles, offering circulars and similar documents
that have been filed with the SEC. As such, FINRA believes it would be
consistent to add shareholder reports that have been filed with the SEC
to that list.
---------------------------------------------------------------------------
\10\ See Section 30 of the Investment Company Act of 1940 and
Rules 30a-1 and 30b1-1 thereunder.
\11\ See proposed amendments to FINRA Rule 2210(c)(7)(F). To the
extent that a member distributes or attaches registered investment
company sales material along with the fund's shareholder report,
such material would remain subject to filing under Rule 2210.
---------------------------------------------------------------------------
Offering Documents Concerning Unregistered Securities
Rule 2210(c)(7)(F) currently excludes from filing ``prospectuses,
preliminary prospectuses, fund profiles, offering circulars and similar
documents that have been filed with the SEC or any state, or that is
exempt from such registration . . .'' (emphasis supplied). The filing
exclusion is intended (and has been interpreted by FINRA) to exclude
issuer-prepared offering documents concerning securities offerings that
are exempt from registration.
Accordingly, FINRA is proposing to amend Rule 2210(c)(7)(F) to make
this intent more clear, and to avoid any confusion concerning the
phrase ``or that is exempt from such registration.'' As revised, Rule
2210(c)(7)(F) would exclude from filing, among other things, ``similar
offering documents concerning securities offerings that are exempt from
SEC or state registration requirements.'' While FINRA believes that
this amendment will clarify this filing exclusion, it does not believe
that it represents a substantive change to the current filing exclusion
for unregistered securities' offering documents.
Backup Material for Investment Company Performance Rankings and
Comparisons
A member that files a retail communication for a registered
investment company that contains a fund performance ranking or
performance comparison must include a copy of the ranking or comparison
used in the retail communication.\12\ When FINRA adopted this
requirement, prior to the Internet, FINRA staff did not have ready
access to the sources of rankings or comparisons. Today, this
information typically is easily available online. FINRA therefore
proposes to eliminate the requirement to file ranking and comparison
backup material and instead expressly to require members to maintain
back-up materials as part of their records.\13\
---------------------------------------------------------------------------
\12\ See FINRA Rule 2210(c)(3)(A).
\13\ See proposed amendments to FINRA Rules 2210(b)(4)(A)(vi)
and 2210(c)(3)(A).
---------------------------------------------------------------------------
Generic Investment Company Communications
FINRA Rule 2210(c)(3)(A) requires members to file within 10
business days of first use retail communications ``concerning''
registered investment companies. FINRA proposes to revise this filing
requirement to cover only retail communications that promote a specific
registered investment company or family of registered investment
companies. Thus, members would no longer be required to file generic
investment company retail communications.
An example of such a generic communication would be a retail
communication that describes different mutual fund types and features
but does not discuss the benefits of a specific fund or fund family.
This type of material typically is intended to educate the public about
investment companies in general or the types of products that a member
offers, and thus does not present the same risks of including
potentially misleading information as promotional communications about
specific funds or fund families.
Investment Analysis Tools
``Investment analysis tools'' are interactive technological tools
that produce simulations and statistical analyses that present the
likelihood of various investment outcomes if certain investments are
made or certain investment strategies or styles are undertaken.
Pursuant to FINRA Rules 2210(c)(3)(C) and 2214(a), members that intend
to offer an investment analysis tool must file templates for written
reports produced by, or retail communications concerning, the tool,
within 10 business days of first use. Rule 2214 also requires members
to provide FINRA with access to the tool itself, and provide customers
with specific disclosures when members communicate about the tool, use
the tool or provide written reports generated by the tool.
Since Rule 2214 became effective in 2005,\14\ FINRA has found that
members have largely complied with the Rule's requirements applicable
to templates for written reports produced by investment analysis tools
and retail communications concerning such tools. FINRA does not believe
that the filing requirements for these templates and retail
communications are necessary given this history and in light of the
investor protection afforded by other content standards and the
requirement that members provide access to the tools and their output
upon request of FINRA staff. Accordingly, FINRA proposes to eliminate
the filing requirements for investment analysis tool report templates
and retail communications concerning such tools and instead require
members to provide FINRA staff with access to investment analysis tools
upon request.\15\
---------------------------------------------------------------------------
\14\ See Notice to Members 04-86 (November 2004).
\15\ See proposed amendments to FINRA Rules 2210(c)(3) and
2214(a).
---------------------------------------------------------------------------
Filing Exclusion for Templates
Members are not required to file retail communications that are
based on templates that were previously filed
[[Page 64242]]
with FINRA but changed only to update recent statistical or other non-
narrative information.\16\ However, members are required to re-file
previously filed retail communications that are subject to filing under
FINRA Rule 2210(c) to the extent that the member has updated any
narrative information contained in the prior filing. Often these re-
filed retail communications are templates for fact sheets concerning
particular funds or products and provide quarterly information
concerning a product's performance, portfolio holdings and investment
objectives.
---------------------------------------------------------------------------
\16\ See FINRA Rule 2210(c)(7)(B).
---------------------------------------------------------------------------
Through its review of updated fund fact sheets and other similar
templates, FINRA has found that certain narrative information has not
presented significant risk to investors, and that these narrative
updates typically are consistent with applicable standards. In
particular, narrative updates that are not predictive in nature and
merely describe market events that occurred during the period covered
by the communication, or that merely describe changes in a fund's
portfolio, rarely have presented significant investor risks. In
addition, members often will update narrative information concerning a
registered investment company, such as a description of a fund's
investment objectives, based on information that is sourced from the
fund's regulatory documents filed with the SEC. In both cases, FINRA
believes that the costs associated with filing these types of narrative
updates exceed the investor benefits associated with FINRA staff review
of these updates.
Accordingly, FINRA proposes to expand the template filing exclusion
also to allow members to include updated non-predictive narrative
descriptions of market events during the period covered by the
communication and factual descriptions of portfolio changes without
having to refile the template, as well as updated information that is
sourced from a registered investment company's regulatory documents
filed with the SEC.\17\
---------------------------------------------------------------------------
\17\ See proposed amendments to FINRA Rule 2210(c)(7)(B).
---------------------------------------------------------------------------
Bond Mutual Fund Volatility Ratings
FINRA Rule 2213 permits members to use communications that include
ratings provided by independent third parties that address the
sensitivity of the net asset value of an open-end management investment
company's bond portfolio to changes in market conditions and the
general economy, subject to a number of requirements. For example,
these communications must be accompanied or preceded by the bond fund's
prospectus and contain specific disclosures. Members currently must
file retail communications that include bond mutual fund volatility
ratings at least 10 business days prior to first use, and withhold them
from publication or circulation until any changes specified by FINRA
have been made.\18\
---------------------------------------------------------------------------
\18\ FINRA Rules 2210(c)(2)(C) and 2213(b) and (c).
---------------------------------------------------------------------------
FINRA believes that some of these requirements have discouraged
members from including bond fund volatility ratings in their
communications due to the significant compliance burdens associated
with doing so, and the level of disclosures required to accompany such
ratings. FINRA has found that, since Rule 2213 first became effective
in 2000,\19\ members have rarely, if ever, filed communications that
contain bond fund volatility ratings. In general, in the few cases in
which members filed such communications with FINRA, the staff has found
that they have met applicable standards.
---------------------------------------------------------------------------
\19\ See Notice to Members 00-23 (April 2000).
---------------------------------------------------------------------------
Given that bond fund volatility ratings may provide useful
information to investors, and that Rule 2213 as currently drafted
appears to have discouraged members from including these ratings in
their communications, FINRA believes it is appropriate to revise the
rule to reduce some of these burdens while continuing to include
requirements that it believes will protect investors. Accordingly,
FINRA proposes to modify some of Rule 2213's requirements.
Consistent with the filing requirements for other retail
communications about specific registered investment companies, the
proposal would no longer require a retail communication that includes a
bond fund volatility rating to be accompanied or preceded by a
prospectus for the fund, and would permit members to file these
communications within 10 business days of first use rather than prior
to use.\20\
---------------------------------------------------------------------------
\20\ See proposed amendments to FINRA Rules 2210(c) and 2213(b).
This change relates only to Rule 2213 and does not affect a member's
obligation to deliver a prospectus under the Securities Act or for
Investment Company Act companies.
---------------------------------------------------------------------------
FINRA believes that the requirement that any retail communication
including a bond fund volatility rating be accompanied or preceded by a
fund prospectus increases the burdens associated with these
communications without adding commensurate investor protection. Except
in rare circumstances due to operational hardship, all mutual fund
prospectuses are available online, and thus an investor can easily
access the prospectus, if needed.
Similarly, FINRA believes that requiring members to file these
retail communications at least 10 business days prior to use and to
withhold them from publication or circulation until any changes
specified by the Department have been made does not provide appreciably
greater investor protection. According to FINRA, this pre-use filing
requirement inhibits a member's ability to circulate retail
communications containing volatility ratings in a timely manner.
Moreover, members still would be required to file these communications
within 10 business days of first use, so that if they contain
misleading content, the Department staff can take appropriate measures
to correct any problems, such as recommending changes to the
communication, or directing the member to cease using the communication
with the public. FINRA has found a post-use filing requirement to be an
effective investor protection approach for most retail communications
with similar risk profiles.\21\
---------------------------------------------------------------------------
\21\ As a general matter, FINRA does not believe that retail
communications that include bond fund volatility ratings present
risks of investor harm that are comparable to other retail
communications that require pre-use filing, such as retail
communications that include self-created rankings or comparisons or
retail communications concerning security futures. See FINRA Rule
2210(c)(2)(A) and (B). Retail communications that include self-
created rankings or comparisons present a greater risk of being
misleading than bond fund volatility ratings, since they are not
created by an entity that is independent of the member. In addition,
security futures are more complex and potentially more volatile than
most bond mutual funds.
---------------------------------------------------------------------------
The proposal also would streamline the content and disclosure
requirements. In particular, the amendments would eliminate the
requirements: (1) That all disclosures be contained in a separate
Disclosure Statement; (2) to disclose all current bond mutual fund
volatility ratings that have been issued with respect to the fund; (3)
to explain the reason for any change in the current rating from the
most recent prior rating; (4) to describe the criteria and
methodologies used to determine the rating; (5) to include a statement
that not all bond funds have volatility ratings; and (6) to include a
statement that the portfolio may have changed since the date of the
rating.
FINRA believes that many of these requirements are unnecessary in
light of the content requirements that still will apply to such retail
communications. For example, members still would not be permitted to
refer to a volatility rating as a ``risk'' rating, and would have
[[Page 64243]]
to incorporate the most recently available rating and reflect
information that, at a minimum, is current to the most recent calendar
quarter end. The criteria and methodology used to determine the rating
still would have to be based exclusively on objective, quantifiable
factors, and such communications would have to include a link to, or
Web site address for, a Web site that includes the criteria and
methodology. Communications would have to provide the name of the
entity that issued the rating, the most current rating and date for the
rating, and whether consideration was paid for the rating, as well as a
description of the types of risks the rating measures.
FINRA believes that, as long as the required disclosures are
provided, it is not necessary that they appear in a separate Disclosure
Statement. FINRA also believes it is unnecessary to disclose all other
current volatility ratings assigned to the advertised fund, since this
requirement is not imposed under other similar rules. For example,
FINRA Rule 2214 allows members to provide fund ranking information
without also requiring the member to disclose all rankings assigned by
other ranking entities. The other disclosure requirements add little
understanding about the rating presented, while adding voluminous text
to the retail communication. In addition, if an investor does seek more
information about the criteria and methodology used to create the
rating, this information will be available via a hyperlink to a
separate Web site.
Proposed Partial Amendment No. 1
In response to comments \22\ (discussed below), FINRA has
determined not to amend its current new member filing requirements, as
set forth in FINRA Rule 2210(c)(1)(A), at this time. It has therefore
deleted the proposed changes to FINRA Rule 2210(c)(1)(A). Although
FINRA believes that it is a close balance between the investor
protection benefits provided by pre-use review and the burden of
complying with the existing rule, FINRA believes that it is more
prudent to defer making the change to post-use filing of new member
retail communications at this time. FINRA will continue to accumulate
more data on the frequency and types of revisions required for new
member retail communications before determining whether to consider any
changes to this requirement in the future.\23\
---------------------------------------------------------------------------
\22\ See PIABA Letter at 2.
\23\ See FINRA Letter at 3.
---------------------------------------------------------------------------
III. Comment Summary and FINRA's Response
As noted above, the Commission received five comment letters on the
proposed rule change \24\ and a response letter from FINRA.\25\ As
discussed in more detail below, four of the commenters generally
supported the proposal, but had some suggestions for changes.\26\ One
commenter opposed the proposal.\27\
---------------------------------------------------------------------------
\24\ See supra note 4.
\25\ See supra note 5.
\26\ See Fidelity Letter, FOLIO Letter, ICI Letter, and SIFMA
Letter.
\27\ See PIABA Letter.
---------------------------------------------------------------------------
Continuation of Retrospective Review
While two commenters generally supported the proposal, both
encouraged FINRA to continue its retrospective review of its rules
governing communications with the public to address other areas.\28\
One commenter recommended that FINRA update its rules governing social
media, mobile devices, and electronic communications, to address the
amount of disclosure FINRA requires in print advertising, and to
eliminate to the extent possible differences among the rules governing
broker-dealer and investment adviser communications, particularly with
respect to communications containing projections or performance
information.\29\ Another commenter recommended that FINRA codify a set
of clear disclosure standards for closed-end fund marketing materials
and to eliminate the filing requirement for these communications.\30\
---------------------------------------------------------------------------
\28\ See Fidelity Letter and ICI Letter.
\29\ See Fidelity Letter.
\30\ See ICI Letter.
---------------------------------------------------------------------------
In its response, FINRA stated that it continues to consider
additional action on its retrospective review of the communications
rules, including those raised by commenters on this proposal.\31\
---------------------------------------------------------------------------
\31\ See FINRA Letter at 2.
---------------------------------------------------------------------------
New Member Filing Requirements
FINRA Rule 2210(c)(1)(A) currently requires new FINRA members to
file with FINRA retail communications used in any electronic or other
public media at least 10 business days prior to use. This requirement
extends for one year from the effective date of the firm's membership.
This new firm filing requirement only applies to broadly disseminated
retail communications, such as generally accessible Web sites, print
media communications, and television and radio commercials. The initial
proposal would have modified this requirement to permit new members to
file these retail communications within 10 business days of first use
for a one-year period, rather than requiring these filings at least 10
business days prior to use.\32\
---------------------------------------------------------------------------
\32\ The proposed change also would delete as redundant current
rule text that permits a new member to file a retail communication
that is a free writing prospectus filed with the SEC pursuant to
Securities Act Rule 433(d)(1)(ii) within 10 business days of first
use rather than at least 10 business days prior to first use.
---------------------------------------------------------------------------
One commenter strongly opposed the proposed change to the new
member filing requirement.\33\ The commenter stated that the proposed
change would eliminate the proactive investor protection that the
current rule affords customers, and that post-use review of all new
member retail communications by FINRA will not provide adequate
investor protection for customers.\34\ The commenter also argued that
the pre-use filing requirement provides a deterrent effect to potential
bad actors, and that a post-use filing requirement would embolden new
members to prepare riskier retail communications.\35\
---------------------------------------------------------------------------
\33\ See PIABA Letter at 1-3.
\34\ See id. at 2-3.
\35\ See PIABA Letter at 2-3. As FINRA stated in its response,
``PIABA also criticized the proposed changes to the new member
filing requirement based on the apparently mistaken belief that the
proposal would differentiate its application between new member Web
sites, and other widely disseminated retail communications.'' See
FINRA Letter at 3 n.5. FINRA therefore clarified that ``although an
earlier version of the proposal contained such a distinction, the
version FINRA filed with the Commission for comment did not.'' Id.
---------------------------------------------------------------------------
Another commenter supported the proposed change to the new member
filing requirement from a pre-use to a post-use requirement, but argued
that FINRA should go further and eliminate the filing requirement
entirely in some circumstances.\36\ This commenter asserted that other
rules and requirements currently in place are sufficient to offer the
important investor protections contemplated by the new member filing
requirement, citing as an example FINRA's new member application
process pursuant to NASD Rule 1013.\37\ The commenter suggested that
FINRA impose the filing requirement only on new members that do not
have compliance or supervisory personnel with at least five years of
experience directly related to sales practice requirements that would
be responsible for reviewing and approving the firm's retail
communications.\38\ Alternatively, the commenter suggested narrowing
the new member filing requirement to exclude generic retail
communications and retail
[[Page 64244]]
communications that contain non-predictive narrative descriptions.\39\
---------------------------------------------------------------------------
\36\ See FOLIO Letter at 1-2.
\37\ See id.
\38\ See id.
\39\ See id.
---------------------------------------------------------------------------
In response to the suggestion by one commenter that FINRA eliminate
the new member filing requirement in certain circumstances and narrow
it in others, FINRA noted that the current rule already contains a
mechanism to provide regulatory relief in the kinds of circumstances
the commenter cited.\40\ FINRA stated in its response that it is
authorized conditionally or unconditionally to grant an exemption from
the new member filing requirement for good cause shown.\41\ Thus, if a
member makes a persuasive case that the new member filing requirement
should not apply to the firm, such as where the new firm is the
successor to an existing firm and its compliance personnel have
demonstrated familiarity with the communications rules, FINRA may
consider granting an exemption from the filing requirement.\42\ In
addition, FINRA noted that even new members are not required to file
retail communications where those communications do not make a
financial or investment recommendation or otherwise promote a product
or service of the member.\43\ Thus, FINRA's view is that truly generic,
non-promotional retail communications need not be filed under this
requirement.\44\
---------------------------------------------------------------------------
\40\ See FINRA Letter at 3.
\41\ See FINRA Rule 2210(c)(9)(A).
\42\ See FINRA Letter at 3.
\43\ See id.; see also FINRA Rule 2210(c)(7)(C).
\44\ See FINRA Letter at 3.
---------------------------------------------------------------------------
After considering all of the comments, FINRA stated that it has
determined not to amend its current new member filing requirements at
this time.\45\ Although FINRA believes that it is a close balance
between the investor protection benefits provided by pre-use review and
the burden of complying with the existing rule, FINRA believes that it
is more prudent to defer making the change to post-use filing of new
member retail communications at this time.\46\ FINRA stated that it
will continue to accumulate more data on the frequency and types of
revisions required for new member retail communications before
determining whether to consider any changes to this requirement in the
future.\47\
---------------------------------------------------------------------------
\45\ See FINRA Letter at 3.
\46\ See id.
\47\ See id.
---------------------------------------------------------------------------
Investment Company Shareholder Reports
FINRA currently requires members to file the management's
discussion of fund performance (``MDFP'') portion of a registered
investment company shareholder report if the report is distributed or
made available to prospective investors. FINRA proposes to exclude from
the FINRA filing requirements the MDFP by adding an express exclusion
for annual or semi-annual reports that have been filed with the SEC in
compliance with applicable requirements.
Two commenters supported this proposed change.\48\ One commenter
noted that this exclusion would make FINRA's rule less burdensome on
asset management firms by eliminating redundant filing
requirements.\49\ Another commenter opposed this change on the ground
that Commission staff does not fully review all regulatory filings made
on the EDGAR system, which is where filings of fund shareholder reports
are made.\50\
---------------------------------------------------------------------------
\48\ See FINRA Letter at 4.
\49\ See SIFMA Letter at 2.
\50\ See PIABA Letter at 4.
---------------------------------------------------------------------------
In its response, FINRA stated that it maintains that the MDFP
portion of shareholder reports should be excluded from the filing
requirements.\51\ FINRA stated that it has found through its filing
program that the MDFPs in shareholder reports rarely have raised issues
requiring members to revise or withdraw reports from circulation.\52\
FINRA acknowledged that Commission staff may not review all securities-
related filings contemporaneous with their submission, but pointed out
in its response that Commission staff can review higher risk
communications as needed.\53\ FINRA stated its belief that this change
would not appreciably impact investor protection and would allow FINRA
to allocate its staff resources more efficiently to focus on reviewing
higher risk communications more expeditiously.\54\
---------------------------------------------------------------------------
\51\ See FINRA Letter at 4.
\52\ See id.
\53\ See id.
\54\ See id.
---------------------------------------------------------------------------
Generic Investment Company Communications
FINRA Rule 2210(c)(3)(A) requires members to file within 10
business days of first use retail communications ``concerning''
registered investment companies. FINRA proposes to revise this filing
requirement to cover only retail communications that promote a specific
registered investment company or family of registered investment
companies. Thus, members would no longer be required to file generic
investment company retail communications.
Two commenters supported this proposed change.\55\ However, one
commenter requested that FINRA clarify how this filing exclusion
interrelates with Securities Act Rule 482.\56\ In response to this
request, FINRA stated in its response that it intends the registered
investment company filing requirement to apply to any retail
communication that is governed by either Securities Act Rule 482 or
Investment Company Act Rule 34b-1, or that otherwise promotes or
recommends a specific registered investment company or family of
registered investment companies.\57\ To the extent that a retail
communication qualifies as a generic investment company advertisement
under Securities Act Rule 135a, FINRA stated that a member would not be
required to file the retail communication.\58\
---------------------------------------------------------------------------
\55\ See FOLIO Letter at 3; see also SIFMA Letter at 3.
\56\ See SIFMA Letter at 3.
\57\ See FINRA Letter at 4-5.
\58\ See FINRA Letter at 5.
---------------------------------------------------------------------------
Filing Exclusion for Templates
Under current rules, members are not required to file retail
communications that are based on templates that were previously filed
with FINRA but changed only to update recent statistical or other non-
narrative information.\59\ However, members are required to re-file
previously filed retail communications that are subject to filing under
FINRA Rule 2210(c) to the extent that the member has updated narrative
information contained in the prior filing.
---------------------------------------------------------------------------
\59\ See FINRA Rule 2210(c)(7)(B).
---------------------------------------------------------------------------
FINRA's proposal would expand the template filing exclusion also to
allow members to include updated, non-predictive narrative descriptions
of market events that occurred during the period covered by the
communication and factual descriptions of portfolio changes without
having to re-file the template. Similarly, a template could include
information that is sourced from a registered investment company's
regulatory documents filed with the Commission without triggering a
requirement to re-file.
Two commenters supported this proposed change, but recommended
amending the proposal.\60\ One of these commenters recommended that the
exclusion cover any non-predictive narrative information that comes
from either an independent data provider or is sourced from an
investment company's regulatory documents filed
[[Page 64245]]
with the Commission.\61\ This commenter recommended that, at the very
least, this filing exclusion cover non-predictive narrative information
that is (1) purchased or licensed directly from a third-party data
provider, and (2) sourced from a Commission document.\62\
---------------------------------------------------------------------------
\60\ See Fidelity Letter at 2-3; see also ICI Letter at 3-4.
\61\ See Fidelity Letter at 2-3.
\62\ See id. at 2.
---------------------------------------------------------------------------
The second commenter recommended that the filing exclusion cover
modifications limited to narrative factual changes provided by any
``ranking entity,'' as such term is defined in FINRA Rule 2212(a).\63\
The commenter also recommended that FINRA broaden the reference to
``non-predictive narrative information that describes market events''
to expressly permit commentary.\64\ Finally, the commenter argued that
otherwise the proposal could be unduly narrow and difficult for members
to apply.\65\
---------------------------------------------------------------------------
\63\ See ICI Letter at 3.
\64\ See id. at 4.
\65\ See id.
---------------------------------------------------------------------------
One commenter opposed this change entirely, arguing that FINRA
should review any narrative descriptions included in retail
communications for misleading information.\66\ The commenter cited
several recent FINRA enforcement cases involving misleading retail
communications as grounds for maintaining FINRA's current template
filing exclusion.\67\
---------------------------------------------------------------------------
\66\ See PIABA Letter at 4-5.
\67\ See id.
---------------------------------------------------------------------------
In its response, FINRA disagreed that Rule 2210 should exclude from
filing any template updates that are based on any non-predictive
narrative information that is sourced from an independent data
provider.\68\ FINRA stated its belief that such a standard could
potentially permit inclusion of non-predictive narrative information
that is intended to promote future sales of a fund, which FINRA
believes should be re-filed.\69\ However, FINRA stated if a member
updates a template based on information that is sourced from a
registered investment company's regulatory documents filed with the
Commission, the update would qualify for this filing exclusion.\70\
FINRA stated that this exclusion would apply even if an independent
data provider supplies the information that is sourced from the
Commission filings.\71\
---------------------------------------------------------------------------
\68\ See FINRA Letter at 6.
\69\ See id.
\70\ See id.
\71\ See id.
---------------------------------------------------------------------------
Further, FINRA stated that it does not agree that the template
filing exclusion should be based on whether narrative factual changes
are provided by a ranking entity as defined in Rule 2212.\72\ FINRA
stated its belief that the better test is whether the information is
sourced from Commission filings, rather than basing it on the
provider's business model.\73\
---------------------------------------------------------------------------
\72\ See id.
\73\ See id.
---------------------------------------------------------------------------
FINRA stated that it does not agree that the template filing
exclusion also should cover commentary.\74\ As one commenter
acknowledged, commentary often includes forward looking statements
about the market or a particular fund.\75\ Accordingly, FINRA believes
these kinds of narrative updates should be re-filed.\76\
---------------------------------------------------------------------------
\74\ See id.
\75\ See ICI Letter at 4 n.10.
\76\ See FINRA Letter at 6.
---------------------------------------------------------------------------
Finally, FINRA stated that it does not believe the enforcement
cases cited by one commenter support its opposition to revising the
template filing exclusion.\77\ Those cases did not involve updates of
templates, but rather instead involved misleading marketing materials
that members would continue to be required to file even after the
proposed change to the template filing exclusion.\78\ FINRA noted that
its members are already required to file mutual fund retail
communications, and to the extent a member is using a retail
communication that becomes misleading due to changes in market
conditions, the member must either cease using the communication or
revise the communication to make it accurate.\79\ If the revision
constitutes a material change to the retail communication, the member
must re-file it.\80\
---------------------------------------------------------------------------
\77\ See FINRA Letter at 6.
\78\ See id.
\79\ See id.
\80\ See FINRA Rule 2210(c)(7)(A).
---------------------------------------------------------------------------
Moreover, FINRA noted, the FINRA Rule 2210 content standards apply
regardless of whether a member re-files a retail communication with
FINRA.\81\ FINRA believes existing standards, even after this change to
the template filing exclusion, strongly protect retail investors from
receiving potentially misleading communications.\82\ Accordingly, FINRA
stated that it is not revising its proposed changes to the template
filing exclusion.\83\
---------------------------------------------------------------------------
\81\ See FINRA Letter at 6.
\82\ See id.
\83\ See id.
---------------------------------------------------------------------------
Bond Fund Volatility Ratings
FINRA Rule 2213 permits members to use communications that include
ratings provided by independent third parties that address the
sensitivity of the net asset value of a bond mutual fund's portfolio to
changes in market conditions and the general economy, subject to a
number of requirements. These requirements include that the
communication be accompanied or preceded by the fund's prospectus, that
it be filed at least 10 business days prior to use with FINRA, and that
it include a number of disclosures. FINRA has proposed to revise these
requirements by no longer requiring such communications to be
accompanied or preceded by a fund prospectus, by allowing members to
file such communications within 10 business days of first use rather
than 10 days prior to use, and by streamlining some of the content
standards and required disclosures.
One commenter opposed these changes on the ground that recent
enforcement actions involving the sale of bond funds demonstrate that
bond funds should be highly regulated.\84\ FINRA responded that
although it agrees that bond funds and members' sales of such funds
should be effectively regulated, it disagrees that the proposed changes
would undermine this goal.\85\ FINRA noted that the commenter did not
allege that any of its cited cases involved communications that
included bond fund volatility ratings, and additionally pointed out
that FINRA has not brought any enforcement actions involving violations
of FINRA Rule 2213.\86\
---------------------------------------------------------------------------
\84\ See PIABA Letter at 5-6.
\85\ See FINRA Letter at 7.
\86\ See FINRA Letter at 7.
---------------------------------------------------------------------------
In addition, FINRA stated that the proposed changes would not alter
a FINRA member's obligation to file retail communications concerning
bond mutual funds.\87\ FINRA stated that the only filing change would
be that retail communications that included a bond fund volatility
rating would have to be filed within 10 business days of first use,
similar to any other retail communication concerning a specific fund or
fund family, rather than at least 10 business days prior to use.\88\
Finally, FINRA stated that Rule 2213 also would continue to impose
content and disclosure requirements that will provide investors with
significant information about the meaning and limitations of volatility
ratings.\89\
---------------------------------------------------------------------------
\87\ See id.
\88\ See id.
\89\ See id.
---------------------------------------------------------------------------
IV. Discussion and Commission Findings
After careful review of the proposed rule change, as modified by
Partial Amendment No. 1, the comment letters,
[[Page 64246]]
and FINRA's response to the comments, the Commission finds that the
proposal, as modified by Partial Amendment No. 1, is consistent with
the requirements of the Exchange Act and the rules and regulations
thereunder that are applicable to a national securities
association.\90\ Specifically, the Commission finds that the rule
change is consistent with Section 15A(b)(6) of the Exchange Act,\91\
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.
---------------------------------------------------------------------------
\90\ In approving this rule change, the Commission has
considered the rule's impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
\91\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
As stated in the Notice, FINRA believes that the proposal will
``enhance the efficiency'' of its communications with the public rules
``with no reduction in investor protection.'' \92\ Specifically, FINRA
``believes that the proposed rule change will improve efficiency and
reduce regulatory burden by reducing the filing requirements applicable
to retail communications distributed by members and streamlining the
content and disclosure requirements for retail communications that
include bond mutual fund volatility ratings, while maintaining
necessary investor protections.'' \93\ With respect to the proposal for
amending the new member filing requirements in FINRA Rule
2210(c)(1)(A), FINRA stated in its response upon consideration of the
comments that were filed in opposition to the proposal, that ``it is
more prudent to defer making the change to post-use filing of new
member retail communications at this time.'' \94\ It therefore filed
Partial Amendment No. 1 on September 1, 2016, in which it proposed that
the new member pre-use filing requirements in FINRA Rule 2210(c)(1)(A)
remain unchanged.\95\
---------------------------------------------------------------------------
\92\ Notice at 39081.
\93\ Notice at 39084.
\94\ FINRA Letter at 3.
\95\ Partial Amendment No. 1.
---------------------------------------------------------------------------
Taking into consideration the comments and FINRA's response and
proposed partial amendment, the Commission believes that the proposal
is consistent with the Exchange Act. The Commission believes that the
proposal promotes regulatory efficiency by selectively streamlining
content and disclosure requirements for retail communications without
undermining strong regulatory protections for investors.
The Commission further believes that FINRA's response, as discussed
in more detail above, appropriately addressed commenters' concerns and
adequately explained its reasons for modifying its proposal to maintain
the current pre-use filing requirement for new member retail
communications. The Commission believes that this modification responds
to one of the primary concerns raised by the commenter opposing the
proposal on the grounds that changing to a post-use filing requirement
for new members would not provide adequate investor protection, and
that a pre-use filing requirement has a deterrent effect on bad
actors.\96\ As noted above, FINRA plans to continue to ``accumulate
more data on the frequency and types of revisions required for new
member retail communications before determining whether to consider any
changes to this requirement in the future.'' \97\ The Commission
believes that the approach proposed by FINRA is appropriate and
designed to protect investors and the public interest, consistent with
Section 15A(b)(6) of the Exchange Act. For these reasons, the
Commission finds that the proposed rule change is consistent with the
Exchange Act and the rules and regulations thereunder.
---------------------------------------------------------------------------
\96\ See PIABA Letter at 2-3.
\97\ FINRA Letter at 3.
---------------------------------------------------------------------------
V. Solicitation of Comments on Partial Amendment No. 1 to the Proposed
Rule Change
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposal, as
modified by Partial Amendment No. 1, is consistent with the Exchange
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-2016-018 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Number SR-FINRA-2016-018. 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 20549-1090, on official business days between the hours
of 10:00 a.m. and 3:00 p.m. Copies of such filing will also 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-2016-018
and should be submitted on or before October 11, 2016.
VI. Accelerated Approval of Proposed Rule Change, as Modified by
Partial Amendment No. 1
The Commission finds good cause to approve the proposed rule
change, as modified by Partial Amendment No. 1, prior to the thirtieth
day after the date of publication of notice of the amended proposal in
the Federal Register. The revisions made to the proposal in Partial
Amendment No. 1 will provide that the current pre-use filing
requirement for new member retail communications remains unchanged, as
currently set forth in FINRA Rule 2210(c)(1)(A). As noted above, the
Commission believes that this modification responds to one of the
primary concerns raised by the commenter opposing the proposal on the
grounds that changing to a post-use filing requirement for new members
would not provide adequate investor protection,\98\ and notes that
FINRA plans to continue to accumulate more data before determining
whether to consider any changes to this requirement in the future.\99\
---------------------------------------------------------------------------
\98\ See PIABA Letter at 2-3.
\99\ See FINRA Letter at 3.
---------------------------------------------------------------------------
Accordingly, the Commission finds good cause, pursuant to Section
19(b)(2) of the Exchange Act,\100\ to approve the proposed rule change,
as modified by
[[Page 64247]]
Partial Amendment No. 1, on an accelerated basis.
---------------------------------------------------------------------------
\100\ 15 U.S.C. 78s(b)(2).
---------------------------------------------------------------------------
VII. Conclusion
It is therefore ordered pursuant to Section 19(b)(2) \101\ of the
Exchange Act that the proposal (SR-FINRA-2016-018), as modified by
Partial Amendment No. 1, be and hereby is approved on an accelerated
basis.
---------------------------------------------------------------------------
\101\ Id.
---------------------------------------------------------------------------
---------------------------------------------------------------------------
\102\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\102\
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016-22418 Filed 9-16-16; 8:45 am]
BILLING CODE 8011-01-P