Comments on Regulatory Notice 08-23

My firm, Colonnade Securities LLC (CRD 144771), is a (k)(2)(i) firm. We only do mergers & acquisitions advisory work and private placements.
We do not touch customer funds, make a market in any security, have an inventory of securities, or need (or have) a clearing relationship.
Based on the outtake below from a newsletter by a leading law firm in Chicago, I am concerned about the fairness of Proposed FINRA Rule 4110(c)(2) to my firm.
We are careful to comply with the minimum capital requirement. Why would we need to retain capital in our business above the minimum?

From a publication of Winston & Strawn, a law firm in Chicago
“Proposed FINRA Rule 4110(c)(2) would prohibit
Clearing Firms and (k)(2)(i) Firms from withdrawing
capital, paying a dividend, or effecting a similar
distribution that would reduce its equity, where such
withdrawals, payments, or reductions in the aggregate
in any 35-calendar-day period, on a net basis, would
exceed 10 percent of the firm’s net worth.”


Stuart Miller
Managing Director
Colonnade Securities LLC
200 West Adams, Suite 2005
Chicago, IL 60606

312.425.8145 v
847.274.4132 c
312.425.8146 f