This should be the first among several steps that the SEC takes to make it easier for regulated firms to electronically deliver all documents. By way of example, broker-dealers should be able to assume, in the absence of client objection, that they may deliver all required disclosure documents electronically.

The printing and transmission of paper documents, many of which go right into the wastebasket, is expensive and wasteful (and anti-green).

Given the legal uncertainty of the FINRA Rule (it is not clear how it can override either SEC requirements or state law requirements), the SEC should also issue at least a no-action letter or, better, still, a formal exemption from SEC rules regarding customer funds that would expressly permit broker-dealers to put a hold on customer funds where abuse is suspected.

Form PF . Having more firms complete the form is just putting private industry effort to waste.

For broker-dealers, the issue this enforcement action raises is whether there is more that they should do to watch for employer misconduct or educate their own customers against salesperson misconduct. For example, should broker-dealers periodically send their customers a notice akin to the SEC's investor alert warning against making payments other than directly to the broker-dealer itself?