Client Alert

The Financial Industry Regulatory Authority is requesting comment on a revised proposal to amend FINRA Rule 2232 governing trade confirmation disclosures. The amendments would require member firms to disclose a “reference price” on customer confirmations for principal transactions in corporate and agency debt securities with retail customers. The FINRA proposal follows a similar revised proposal by the Municipal Securities Rulemaking Board which would require firms to include mark-ups/mark-downs on trade confirmation disclosure. Both the MSRB and FINRA proposals respond to comments to prior proposals but differ somewhat in detail. The primary difference between the revised proposals is that the MSRB proposal would specifically require disclosure of mark-ups and mark-downs while the FINRA pricing information disclosure would not specifically be disclosure of mark-ups or mark-downs.

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