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SIFMA asked FINRA to reduce the burdens of compliance with a proposed reporting rule concerning employee accounts, and move toward a system based on principles instead of rigid requirements. Specifically, SIFMA recommended changes in FINRA's proposal to (i) adopt FINRA Rule 3210 ("Accounts at Other Broker-Dealers and Financial Institutions") in the Consolidated FINRA Rulebook and (ii) delete incorporated NYSE Rules 407 ("Transactions - Employees of Members, Member Organizations and the Exchange") and 407A ("Disclosure of All Member Accounts"), as well as related Incorporated NYSE Rule

Commentary by Siteadmin Administrator

SIFMA criticized FINRA's proposed Rule 3260 ("Discretionary Accounts and Transactions") (the "Proposal"). The Proposal addresses the treatment of customers' free credit balances and sweep programs, the bulk transfers of customers' accounts and changes of the broker-dealer of record. SIFMA's criticisms of the Proposal included the following: The signature requirement for authorized persons under Proposed Rule 3260(b) raises significant operational, cost, regulatory and other concerns with no investor protection benefit. The Proposal's update requirement will result in a significant