BDA today filed with FINRA a letter in response to FINRA Notice 25-04, “FINRA Launches Broad Review to Modernize Rules Regarding Member Firms and Associated Persons.” The Notice states that FINRA “is launching a broad review of its regulatory requirements applicable to member firms and associated persons.” The Notice also states “FINRA…requests comment on other areas FINRA should consider as part of this review. These comments will help inform and guide the direction of the review, particularly with respect to areas FINRA should prioritize and the initial steps that may be most impactful.”
In response, BDA’s letter focuses on the following areas:
- TRACE trade reporting and FINRA’s recent decision to rescind last year’s one-minute reporting requirement;
- Reporting block trade allocations for dually registered Broker-Dealer/Investment Advisor firms;
- Margin requirements for new-issue agency MBS that FINRA finalized last year;
- Rule coordination with the MSRB;
- FINRA’s “gift rule,” which FINRA has already proposed to amend;
- A request for additional guidance on certain calculations specified in regulation;
- A request for clarity around market movements and calculating Prevailing Market Price; and
- Examinations for compliance with SEC Rule 15c2-11 with respect to bond quotations.
BDA’s letter is available here. Thanks to all who contributed to this project. Please call or write with any questions or reactions.