FINRA Requests Comment on Proposed Exemption from Trading Activity Fee for Proprietary Trading Firms (Regulatory Notice 15-13) (with Lofchie Comment)

FINRA issued a regulatory notice requesting comments on its proposed exemption for proprietary trading firms from the trading activity fee ("TAF").

Regulatory Notice 15-13 explains that the SEC's proposed amendments to Exchange Act Rule 15b9-1 would require a proprietary trading firm relying on the current exemption to register with FINRA if the firm continued to engage in over-the-counter trading, or trading on an exchange of which it was not a member

The notice explained that the require a proprietary trading firm relying on the current exemption to register with FINRA if the firm continued to engage in over-the-counter trading, or trading on an exchange of which it was not a member. In turn, membership with FINRA would subject such a firm to FINRA's fee structure. For that reason, FINRA is requesting comments on a proposed exemption for such firms for certain TAF fees.

Comments must be submitted by June 19, 2015.

Lofchie Comment: Affected firms would be wise to comment on this matter. They also should explain why higher fees might be unfair to them, if that is the case, instead of merely stating that they prefer to pay less.

See: FINRA Reg. Notice 15-13. Related news: SEC Proposes Amendments to Require Off-Exchange Broker-Dealers to Become Members of National Securities Association (Fed. Reg.) (with Lofchie Comment) (April 2, 2015); SEC Proposes Rule Amendments to Require Off-Exchange Broker-Dealers to Become Members of FINRA (with Delta Strategy Group Summary and Lofchie Comment) (March 25, 2015).