Milligan v. Merrill Lynch
Court: U.S. Court of Appeals (Fourth Circuit) Amicus Issue: Whether an employee can retrospectively recast deferred compensation programs as “ERISA…
SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) in response to FINRA’s requests for comment on a rule proposal to implement the Comprehensive Automated Risk Data System (CARDS).
SIFMA believes that FINRA’s CARDS proposal would impose undue costs and burdens on the member firms, and is an attempt to diagnose a regulatory ill without appropriately accounting for the impact on investor privacy and civil liberties, and should not be filed with the Securities and Exchange Commission (SEC).
Related Material
Press Release: SIFMA Submits Comments Highlighting Significant Concerns with the FINRA CARDS Rule Proposal – December 1, 2014
SIFMA Submits Supplemental Comments to FINRA on Proposal to Develop the Comprehensive Automated Risk Data System (CARDS) – July 1, 2014
SIFMA Submits Comments to FINRA on Developing the Comprehensive Automated Risk Data System (CARDS) – March 21, 2014
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