SIFMA Submits Supplemental Comments to FINRA on Proposal to Develop CARDS

SIFMA submitted supplemental comments to FINRA on its concept proposal to develop the Comprehensive Automated Risk Data System ("CARDS"). SIFMA stated that its comments are intended to encourage FINRA to publicly address certain remaining issues with CARDS as it continues to consider the concept.

In March 2014, SIFMA filed a comment letter that expressed a range of significant concerns with the CARDS concept. SIFMA urged FINRA to make public its cost-benefit analysis with respect to the CARDs rules. SIFMA urged FINRA to work with the SEC and other SROs to ensure that the new CARDS reporting would not be "duplicative or superfluous," or overlap with the consolidated audit trail. SIFMA also asserted that the collection of the CARDS information put customers at material risk of the loss of confidential information.

See: SIFMA Comment Letter.Related news: SIFMA Objects to FINRA Proposal Regarding CARDS Concept Proposal (with Lofchie Comment) (March 21, 2014).