Subject: File No. SR-FINRA-2007-011
From: William D. Lyons
Affiliation: Westminster Securities Corporation

January 30, 2008

Ms. Nancy M. Morris
Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090

Re: File Number SR-FINRA-2007-011

Dear Ms. Morris:

Thank you for the opportunity to comment on the Rule Proposal of the Financial Industry Regulatory Authority (FINRA) to amend FINRA Rule 2711 and FINRA NYSE Rule 472 regarding a member firm’s disclosure and supervisory review obligations when distributing third-party research (Amendment 1 to SR-FINRA-2007-011 filed on January 16, 2008).

The proposed texts of FINRA Rule 2711, (h) (13) (C) (b) and FINRA NYSE Rule 472, (k) (4) (iii) (2) make reference to any required review of third party research being carried out by a registered principal or supervisory analyst “based on information otherwise possessed by the member“ and “based on information otherwise possessed by the member organization,” respectively.

In light of the likelihood many, if not most, such reviews will be carried out by supervisory persons who are employees of each member firms’ respective research departments and the fact that current regulation and industry practice have created significant limitations on communication and information exchange between members’ research departments and their other operating units, we believe the texts of FINRA Rule 2711, (h) (13) (C) (b) and FINRA NYSE Rule 472, (k) (4) (iii) (2) should be revised.

Specifically, we suggest these rules should include language that reflects the fact that a principal or supervisory analyst assigned by a member firm to carry out the review of third party research may not be aware of all information his or her member firm employer possesses regarding a specific company, industry, etc. We respectfully request that FINRA Rule 2711 and FINRA NYSE Rule 472 refer to such reviews being performed based on information that can reasonably be expected to be in the possession of the reviewer (rather than the corporate knowledge of the reviewer’s entire firm).

Thank you again for providing us the opportunity to comment on the proposed changes to FINRA Rule, 2711 and FINRA NYSE Rule 472, which we believe are in the best interest of investors and will expand the quantity of company and other research available to most investors.

If you have any questions about this request, or if we can provide additional information, please contact the undersigned.

Sincerely,

Mr. William D. Lyons
Director of Equity Research
Westminster Securities Corporation
Six Concourse Parkway, Suite 1460
Atlanta, GA 30328
Phone: (678) 578-0470
E-mail: wlyons@westminstersecurities.com

Mr. Arkadiy Neyman
Chief Compliance Officer
Westminster Securities Corporation
100 Wall Street, 7th Floor
New York, NY 10005
Phone: (212) 878-6583
E-mail: aneyman@westminstersecurities.com