BDA today submitted comments to FINRA in response to FINRA Notice 20-42, “FINRA Seeks Comment on Lessons From the COVID-19 Pandemic.” FINRA requested comment on how firms have managed through the pandemic and what actions FINRA should take going forward.
The letter can be viewed here.
BDA told FINRA “Firms have generally reported that after the market disruption of February and March 2020, the industry and the market recovered surprisingly quickly. Every firm we talked with reported that they have been operating at full capacity with no break in their ability to service customers and provide liquidity.”
We also said “Remote work will be part of the ‘new normal even after the pandemic recedes, and FINRA rules should accommodate this. Dealers have demonstrated over the last year that they can effectively manage and supervise employees remotely, and the FINRA rulebook should support this kind of work arrangement.”
We anticipate a similar request for comment from the MSRB on issues related to the pandemic and remote work. We will follow up with FINRA on the points we raise in our letter. As always, please call or write with questions or comments.