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Commentary by Steven Lofchie

FINRA filed with the SEC a proposal to adopt new FINRA Rule 2242 to address conflicts of interest relating to the publication and distribution of debt research reports. As anticipated, the proposed debt research rule is based on FINRA's existing equity research rule (NASD Rule 2711), but contains important modifications that FINRA considers necessary to reflect the differences between the equity and debt markets. First, the proposed debt research rule would adopt a "tiered approach" that distinguishes between debt research distributed to retail investors on the one hand, and institutional