SIFMA`s clearing Firms Committee provided comments to the Financial Industry Regulatory Authority, Inc. (FINRA) in response to FINRA Regulatory Notice 18-10; FINRA`s request for an opinion on the effectiveness and efficiency of its delegation agreement rule, FINRA Rule 4311 (Rule 4311). 1. Is the rule effective in ensuring a clear division of competences between the parties to a promotion agreement? If not, why not? Are there any additional responsibilities that the rule should expressly impose? Are there responsibilities that should not be assigned as a rule? What for? If you are using a form of transport agreement previously approved in accordance with FINRA Rule 4311(b)(2), please indicate the form and date of approval of this form by FINRA: 11 Since carrier companies are generally finra members, finra expects that applications for promotion agreements with non-FINRA member companies will be rare. Please note that FINRA Rule 4311(b)(4) requires each exporting company to perform appropriate due diligence with respect to any new business relationship in order to assess the financial, operational, credit and reputational risk that such an agreement risks to the carrier company. The following questions are representative of the nature of the verifications that will be expected of undertakings in the context of their corresponding due diligence in accordance with this Rule. . . .