MFA Submits Additional Comments to SEC on FINRA Rule 5123

December 03, 2013

From: MFA, Stuart Kaswell

To:

Elizabeth Murphy, SEC
John Ramsay, Norman Champ, Keith Higgins, SEC; Richard Ketchum, Robert Kolby, Racquell Russell, FINRA

MFA submitted comments to the SEC in response to its notice of the Financial Industry Regulatory Authority’s (“FINRA”) amendments to Rule 5123. The amendments would require broker-dealers to provide additional information about an issuer to FINRA, along with a PPM or other disclosure document, in connection with certain private placements conflicts. In the letter, MFA requests that FINRA respond to our previous comments about the scope of the amendments and Rule 5123, the authority of FINRA in implementing the Rule, and the expedited approval process, which did not include a formal notice and comment period prior to adoption of the amendments. MFA continues believing that these issues merit careful consideration by both FINRA and the SEC, and MFA asks that FINRA provide a response to these comments and other similar concerns that market participants have raised.

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