Selection Specifications & Study Outline for the Operations Professional Examination Program

The Compliance and Regulatory Committee of SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s Notice of Filing and Immediate Effectiveness on a proposed rule change to adopt the selection specifications and content outline for the Operations Professional (Series 99) examination program, Release No. 34–65222; File No. SR–FINRA– 2011–041. The Series 99 was filed in connection with FINRA Rule 1230(b)(6), a new representative registration category and qualification examination requirement for certain operations and other personnel.  SIFMA believes that the industry professionals who were involved in developing the Series 99 exam may have had such a depth of specialized operational expertise that, in some cases, the level of detail in certain questions in the exam question bank is overly granular and the exam questions do not sufficiently emphasize the importance of identifying and escalating red flags relating to the covered functions.