BDA today provided comments to FINRA in response to their review of regulations that affect “member workplaces.”
FINRA states in their Notice “As part of the broad rule modernization review, this Notice seeks comment on how FINRA can further evolve its rules, guidance and processes to reflect modern business practices and markets; support innovation and new technologies; promote efficiency; and eliminate unnecessary regulatory burdens—all in the interest of supporting vibrant capital markets in which everyone can participate with confidence.”
BDA addressed FINRA’s supervision rule, among other issues. We told the SRO “FINRA’s location-based supervision model is antiquated and obsolete. Principals no longer supervise their employees through physical proximity. They use technology which is not location-dependent whatsoever. The idea that certain activities can only be performed in certain offices with certain designations is not consistent with how modern broker-dealers are managed and operated.”
Our letter also addressed issues such as testing and licensing, continuing education, and record keeping, among others. Thanks to all who contributed to this project. BDA’s letter is available here.