SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) opposing the FINRA proposal to develop the Comprehensive Automated Risk Data System (CARDS), Regulatory Notice 13-42.

Without more information about required data elements, data standardization, other technical details regarding the reporting platform, transmission methods, an analysis of other current and proposed reporting requirements, and an explanation of how the data will be stored, protected and used, SIFMA cannot conduct the necessary fulsome cost and benefit analysis of the proposal to conclude that the proposal should be supported. Nevertheless, SIFMA provides its initial general comments on the proposal and its responses to the specific questions contained in the proposal.

Moreover, because the proposal involves significant and controversial issues, if FINRA determines to move forward with the proposal, SIFMA urges FINRA to work closely with the industry to address the technical, compliance and legal questions prior to the proposal being published for comment as a proposed rule.