Rule 15c2-11 is useful in the equities market. The same framework does not work for fixed income securities. The application of the rule to fixed income securities was made with insufficient notice and thus a lack of guidance from the public. The number and extent of the no-action relief for fixed income securities shows how poorly the rule works for fixed income securities I spent six years with SEC Enforcement, 12 years with FINRA's Market Regulation Department, and 11 years in other aspects of the industry.