2023 Small Firm Conference: A Fireside Chat with Robert Cook
The small firm community, those firms with 150 or fewer registered financial professionals came together in October to discuss and engage on key areas of concern at the Small Firm Conference. On this episode, we go behind the scenes of this year's event to share with you the fireside chat between FINRA CEO Robert Cook and FINRA's Head of Member Relations, Kayte Toczylowski.
Resources mentioned in this episode:
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00:00 - 00:22
Intro: The small firm community, those firms with 150 or fewer registered financial professionals came together in October to discuss and engage on key areas of concern at the Small Firm Conference. On this episode, we go behind the scenes of this year's event to share with you the fireside chat between FINRA CEO Robert Cook and FINRA's Head of Member Relations, Kayte Toczylowski.
00:22 – 00:36
00:36 - 00:56
Kayte Toczylowski: I am thrilled to welcome to the stage FINRA President and CEO Robert Cook to chat with us about his perspective on the small firm community and set the tone for the sessions to follow. Hello.
00:56 - 00:57
Robert Cook: Hey, Kayte.
00:57 - 00:58
Kayte Toczylowski: Thanks for being here, Robert.
00:58 - 01:08
Robert Cook: My pleasure. Great to be here. And let me just echo Kayte's welcome to all of you. It's great to see all of you here and I look forward to a great conversation, and look forward to meeting many of you at these networking moments that Kayte was just mentioning.
01:10 - 01:25
Kayte Toczylowski: Fantastic. Yes, take the opportunity to introduce yourself to Robert. So, Robert, as I just mentioned and underscored: the importance of the small firm community as they represent such a huge portion of FINRA's membership. So, that's where I was hoping to start. If you can share your perspectives on this community and what it means to the industry.
01:29 - 02:05
Robert Cook: Well, sure. And this is a topic we've talked about at various of these moments at the Small Firm Conference, and this is one of my favorite conferences, by the way. I just love the opportunity to interact with the small firms. You mentioned it right at the top—small firms are 90 percent of our membership. So, obviously, as an SRO, having those opportunities to interact with 90 percent of our membership really matters. So, we're especially grateful for you to take the time to be here with us today. But there are other dimensions to it as well. Small firms really represent such a diverse variety of business models. And that's both exciting—the diversity in the membership and in the business models that makes a vibrant industry—it's also challenging, because it means that there are so many different types of customer interactions, market interactions, that we need to think about when we're crafting rules or oversight procedures. So, that dialogue with the small firm community is really important to make sure that we're differentiating, as appropriate, between different types of small firms.
Small firms also tend to be, in some ways, the incubators for new and emerging types of business models. And so, interacting with the small firm community is very helpful for us to see what are some of the new trends and challenges and opportunities that are coming forward. And I think another piece of it, though, goes well beyond our industry. If you think about small business in general, small businesses are part of their local communities. They interact with and provide services to local communities who might not otherwise have those services. Their kids go to the same school, they go to same house of worship. So, they're so impactful to our investor base in ways that we really want to be aware of and take into account. And I think it's also true if you look at small businesses more generally, most businesses in the U.S. are small businesses. Most of the new jobs are created by small businesses. Almost half of the workforce works for private small businesses. So, the trend is beyond our industry. But within that context, I think it helps underscore the importance of our working closely with our part of that small business community. And we're so grateful to have people here today to help do that.
03:48 - 04:22
Kayte Toczylowski: It's a really great perspective on the importance of this community and all the work that you do in order to benefit those communities that you come from. So, let's dig into some of the challenges that we've heard. Now, you and I meet with various small firms in lots of different forums all throughout the year, and a lot of the feedback we hear with the challenges that small firms face comes with scalability and the tough time small firms have with potentially limited resources in order to invest in vendor solutions, limited resources when it just comes to headcount and there's not enough hours in the day or people to do all that needs to be done within the regulatory world. And I know this has been a focus of FINRA in order to build education programs such as this—resources, tools. So, to help the small firms in order to comply with some of these challenges, I was hoping you could spend a few minutes talking about FINRA's focus and how we use that firm feedback in order to give them resources they can use.
06:44 - 07:09
Robert Cook: Yeah, it's such an important question, Kayte. And you're right, we do hear this all the time when we're meeting with various firms. And it's a reality that there are economies of scale when it comes to compliance. And that's something we have to be very thoughtful about, both when we're crafting the rules up front; so, what are the expectations? What are the standards we're setting and to what extent can we tailor, differentiate, provide appropriate exemptions and the like to address the unique concerns of smaller firms? But it also then comes into play when we're thinking about how do we then help support those firms’ compliance with the rules? I think that's an area that I've been excited that for some time we've been trying to work at it. I don't think we're ever going to be done, right? It's constantly learning about two things that are challenging and where this feedback is really important. One is what's the content that we can provide or what are the tools we can provide? And the second is, how can we make people aware of those tools? Because a big problem we have often is sometimes people say, 'it would be nice if you had this,' and well, we do, but people don't know about it.
So, developing, continually, new types of resources is incredibly important. I know your team spends a lot of time thinking about this, but whether it's new types of templates, compliance guides, checklists, conferences like this, webinars. How do we make sure that we're hitting on the most timely and difficult topics? It's with help from you. So, that's where your continual feedback saying, ‘hey, it'd be great if you address this or if you address that’ would be really valuable. We get that through a variety of mechanisms. We can't always do everything, but I can assure you, we do want to hear regularly about where you think those resources would be helpful. But we also need your help in thinking about how we make sure that the community beyond, people who don't necessarily get to attend a conference like this, how do we make sure they're aware, ‘hey, there's this new podcast’—it's great, but we need people to listen. Or we got the small firm conference calls, great, but we need people to know about the Member Hub, which was recently created on our website to help pull together all of these recent resources in a user-friendlier way than having to go to this part of the website or that part of website. Great innovation—another example of trying to make it simpler to get those resources. But we want to continue to get feedback about how we can get the message out.
07:19 - 07:50
Kayte Toczylowski: You mentioned some fantastic resources, and if you haven't used the new Member Firm Hub, it is right on the home page of finra.org. We have a section for media, for investors. And now you'll see a section that says ‘For firms.’ So, if you haven't used it yet, it is a fantastic resource. I want to build upon an item that you talked about quite a bit already today, and that is we want firm feedback. So, I'm sure there are some firms in the room that serve on committees that have been to outreach events that you and I do; but for others that haven't taken part in those, what are some other ways that you want to highlight for firms to connect with FINRA?
07:57 - 08:26
Robert Cook: We're always looking for, again, ideas about what more we could do. The lifeblood, I think, of an SRO is that feedback loop, that interaction with our membership. And one of the key ways we do that is through our committee structure. So, we have various advisory committees. We've been trying to provide more transparency about what they are, who's on them. But whether it's things like our standing advisory committees that look at every rule that goes up to the Board, to special committees that may be convened for specific purposes, there are committees around things like the continuing education program or the testing program, and people on those committees put in a lot of work. They really do, and I'm very grateful for that. That's on top of their day job, so to speak. But it's incredibly important for us to get that flow of new ideas. So, the committee structure would be one thing to think about. There are other opportunities for service, especially if you've been on one of these committees. There's our Office of Hearing Officers. You can serve on one of the enforcement hearings. You have to, I think, have been on a committee to do that at some point. But that's another incredibly time intensive, real service that people in the industry provide to the industry.
There's our National Adjudicatory Council, which is an elected and appointed body that hears appeals of any enforcement matters. And then there's our Board, and there's opportunities to be elected to the Board. We have three small firm governors on the Board. Two of them will be here today. Linde Murphy is here, and Wendy Lanton might be here or coming soon. And Paige Pierce is also on the Board. Really important way to hear, for the small firm community voice to be heard, at the level of the Board. And of course, a Small Firm Advisory Committee, one of our standing committees that I mentioned that does hear all of the matters that are rising up to the level of the Board. There are elected and appointed members there. All these committees, we've been working really hard to make sure it's not a clique. We publish a Notice every year that says, ‘hey, these are all the committees and this is how you can get involved in them.’ We also have term limits. So, the membership of the committees rolls over some period of time so that we can get new voices coming in, it means we have a lot more work to do sometimes populating these committees, but it's worth it. And we also have a portal on our website. You can go to express interest in any one of these committees, and I encourage you to go there. You can always go to any of us and Kayte's team in particular if you're wondering about how to get involved, if you're interested in a particular committee, please, please reach out.
So, those are some of the mechanisms that we use to hear the voice of the membership. And it's really important. There are others as well. We’ve got the comment process, which we've tried to make easier by allowing you to just enter comments right on the website. That's if there's a rule or some paper we have, but not all firms have the time to do that. But I think getting involved in some of these committees, or just reaching out to Kayte's team and raising concerns, reaching out to your Risk Monitoring Analyst and having that conversation and sharing your perspectives. There are mechanisms within FINRA so we can take that feedback back and use it.
11:16 - 11:38
Kayte Toczylowski: Thanks, Robert. I wanted to further underscore a couple of things you just noted, especially with the Regional Committees and the Small Firm Advisory Committee. You may have noticed that we just opened elections for both of those committees, and I urge you all to vote. Your vote matters and it makes a difference. So, take a look at the candidates that are running. Some of them might be here today. So, there's a challenge for you. Try to seek out who's running and then you can meet them in person while you're here.
11:43 - 11:59
Robert Cook: I knew I was going to forget some committees. The Regional Committees, of course, you just mentioned. I just forgot—we had a great meeting yesterday with the West Region Committee. And again, another way in which people are making time to help serve on these committees that have a meaningful impact on how we do our work. And we're very grateful for that.
12:02 - 12:09
Kayte Toczylowski: Robert, thank you so much for giving us your time this afternoon. It's so great to have you here with us in the small firm community.
12:09 - 12:13
Robert Cook: My pleasure. I look forward to the opportunity to meet many of you at those various networking sessions and the evening one as well.
12:14 - 12:17
Kayte Toczylowski: Fantastic. I hope you enjoy the rest of the conference and I look forward to meeting all of you. Thanks for being here.
12:22 - 12:40
Outro: Well, that is it for today's episode of FINRA Unscripted. Listeners, if you don't already, you can subscribe to FINRA Unscripted wherever you listen to podcasts. And if you have any thoughts on today's episode or ideas for future episodes, you can email us at [email protected]. Today's episode was produced by me, Kaitlyn Kiernan, coordinated by Hannah Krobock and engineered by John Williams. Until next time.
12:40 – 12:49
12:49 - 13:12
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