The Securities Industry Association (SIA)* provides comments to the Financial Services Authority (FSA) on Consultation Paper 171. SIA suggests whichever approach is used for soliciting investment banking business, regulators should clarify that they do not intend to proscribe the ability of research analysts to communicate with an issuer prior to receiving an investment banking mandate to determine if the transaction is in the interests of investors. SIA also suggests that the FSA withdraw the requirement as to whether a firm expects to have an investment banking mandate or to manage any issues of securities for a subject company within 6 months and to replace it with clear language in research reports warning recipients that they should assume that the firm seeks or intends to seek investment banking business with the subject company.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.