SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) on proposed Rule 4516 – Books & Records that would require clearing and carrying firms to maintain and keep current delineated records in a central location to facilitate the rapid and orderly transfer of customer accounts in the event of liquidation or another event necessitating account transfer, FINRA Regulatory Notice 11-48.  While SIFMA is fully supportive of FINRA’s goals to adopt rules that enhance investor protection and reduce risks that arise upon the occurrence of extraordinary market and industry events when such rules are deemed necessary, SIFMA does not believe the requirements of proposed Rule 4516 are the most effective and efficient means to address these concerns.