On April 12, 2017, the Financial Industry Regulatory Authority (“FINRA”) requested comments to proposed amendments to its equity research rule (Rule 2241) and its debt research rule (Rule 2242) to provide a limited, non-exclusive safe harbor for brief, written analysis distributed to eligible institutional investors by sales and trading or principal trading personnel, more commonly known as “desk commentary.” Desk commentary is generally brief, near-term focused and prepared and disseminated quickly in response to trading or news events; generally, the level of analysis contained in desk commentary is insufficient to meet the definition of “research report” under FINRA Rules 2241 and 2242. Because of the broad definition of “research report" under the current equity and debt research rules, however, certain desk commentary may technically fall within the four corners of that definition, triggering a range of consequences under FINRA rules, such as the establishment of information barriers between research and investment banking personnel and the observation of publication blackout dates, securities trading restrictions and limitations on the author’s compensation.