Regulatory Notice 15-22
SIFMA provides comments to FINRA on Regulatory Notice 15-22, a proposed rule regarding member firms’ supervisory requirements for discretionary accounts and transactions. The Proposal would be adopted in the Consolidated FINRA Rulebook as new FINRA Rule 3260. SIFMA applauds FINRA’s continued efforts to streamline the Consolidated FINRA Rulebook by grouping together rules that apply to similar subject matter and eliminating obsolete or duplicative rules. With respect to the Proposal, SIFMA supports FINRA’s goal of preventing unauthorized and excessive trading in discretionary accounts by member firms and their associated persons. Notwithstanding this support, SIFMA recommends several changes to the Proposal to better align its costs with its investor protection benefits, including changes to the Proposal’s manual signature requirement and the types of accounts covered by the Proposal (such as 10b5-1 plans, orphaned accounts, and certain assets held directly).
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