Comments on Regulatory Notice 08-24
As an interested party, I am opposed to the proposed elimination of Rule 3040 and implementation of Rule 3110(b)(3). We believe the three points cited below constitute a strong legal and business argument for this position:
- The proposed rule would subject both the RIA and Broker/Dealer to possible Reg. S-P (customer privacy) violations
- The proposed rule would subject the RIA to a duplicative regulatory environment, in that both the SEC and FINRA would have supervisory oversight, whereas only the SEC currently has jurisdiction. NTM 08-24 goes to great lengths to provide an exemption to banks and should provide for such an exemption for RIA’s.
- The duplicative regulatory structure would increase costs for both RIA Firms and Broker/Dealers.
John D Williams, CFP®, CIMA
Williams Financial Group, Inc.
950 United Center
Charleston, WV 25301