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Molly Dresden Comment On Regulatory Notice 25-05

The proposal is a step in the right direction but could be simplified to make it easier to read in conjunction with other rules. I think it needs more explanation as to the historical reasons behind distinguishing between registered persons and associated persons, and clarification in other rules like 3210 where they are referred implicitly by the rule saying "No person associated with a member" instead of "Associated Person", which is how the text appears in 1011. The proposal seems to blur the actual lines between the two.

Regulatory Notice 25-06

A vibrant and efficient capital-raising process fosters business expansion, job creation, innovation and economic growth. FINRA members play a critical role in facilitating capital formation for businesses of all sizes. FINRA supports the capital-raising process through appropriately tailored rules for its members that are designed for the benefit of all market participants.