On November 28, the Financial Industry Regulatory Authority (FINRA) requested comment on its proposal to adopt a new FINRA Rule 4530 to replace both NASD Rule 3070 and NYSE Rule 351, existing rules that generally require members to report adverse regulatory actions. FINRA highlighted key changes that would apply to the rule as proposed. For example, although the new rule continues to require reporting regarding findings of violations by external bodies, it would also now require reporting whenever a member firm has concluded on its own that an associated person of the firm or the firm itself has violated applicable financial or investment-related laws or rules (including foreign bodies), as is currently required under NYSE Rule 351. This broad reporting requirement would be balanced by commentary from FINRA that it would not expect firms to report isolated violations that could reasonably be viewed as ministerial, did not result in customer harm and were remedied promptly. FINRA’s Regulatory Notice announcing the proposed rule describes all aspects of the proposed rule and also provides a summary in chart form of how its requirements relate to the existing requirements of NASD Rule 3070 and NYSE 351. The comment period expires on December 29.