August 23, 2022

VIA ELECTRONIC MAIL ([email protected])

Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re: Proposed Rule Change to Adopt Supplementary Material .19 (Residential Supervisory Location) under FINRA Rule 3110 (Supervision); File No. SR-FINRA-2022-019; Release No. 34-95379

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates this opportunity to provide the Securities and Exchange Commission (the “Commission” or “SEC”) with comments in response to the Financial Industry Regulatory Authority Inc.’s (“FINRA”) File No. SR-FINRA-2022-019: Proposed Rule Change to Adopt Supplementary Material .19 (Residential Supervisory Location) under FINRA Rule 3110 (Supervision) (the “Proposal”).2

SIFMA and its members would like to thank the SEC, FINRA, and their staff for their extraordinary efforts during the COVID-19 pandemic. The SEC and FINRA have been outstanding partners in coordinating with the industry and responding to the various challenges presented by COVID-19. As we continue to navigate these uncertain times, we anticipate our engagement with the SEC and FINRA will continue to be collaborative as we determine how to regulate in a post-COVID-19 world.

SIFMA appreciates the significant effort that FINRA and its staff have invested in the Proposal, which reflects meaningful input from fellow regulators and the industry. SIFMA supports the Proposal and commends FINRA for modeling the Residential Supervisory Locations classification after the longstanding primary residence and non-primary residence exclusions that have been in effect since 2005. Given the current and anticipated state of hybrid work and the supervision arrangements regarding them, SIFMA encourages swift adoption of the Proposal. SIFMA also requests that the SEC and FINRA consider a few modifications to the Proposal, as outlined in this comment letter.

1 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the United States and global capital markets. On behalf of our industry’s nearly one million employees, we advocate for legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (“GFMA”).

2 FINRA, Proposed Rule Change to Adopt Supplementary Material. 19 (Residential Supervisory Location) under FINRA Rule 3110 (Supervision), File No. SR-FINRA-2022-019, 87 Fed. Reg. 47248 (Aug. 2, 2022), https://www.finra.org/rules-guidance/rule-filings/sr-finra-2022-019.