Front Running of Block Transactions

SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on Front Running of Block Transactions, Regulatory Notice 08-83. The proposal would codify the amended Front Running Policy in new Rule 5270 and related Supplementary Material and would significantly broaden the scope of transactions subject to the rule beyond equities, options and security futures to also include other derivatives, financial instruments and financial contracts. Given the significance and scope of the proposed changes, we appreciate that FINRA determined to seek comment from member firms before the proposal is submitted to the Securities and Exchange Commission (SEC) for public notice and comment.