Keaton Capital Management L.L.C. Comment On Regulatory Notice 25-05

Ms. Jennifer Piorko Mitchell Office of the

Corporate Secretary FINRA

1700 K Street

Washington, DC 20006

Re: Request for Comment on Regulatory Notice 25-05

Dear Ms. Mitchell,

As an owner of a Registered Investment Advisory (RIA) firm having registered representatives at a member firm that is independent and not affiliated in any manner with my RIA firm, I strongly object to the newly proposed Rule 3290 in Regulatory Notice 25-05.

2022074103601 Goldman Sachs & Co. LLC CRD 361 AWC vr (2025-1749773999194).pdf

Between June 2020 and June 2023, Goldman failed to accurately report data for 36.6 billion equity order events to the CAT Central Repository in violation of FINRA Rules 6830, 6893, and 2010, and had related supervisory failures in violation of FINRA Rules 3110 and 2010... Between October and November 2021, Goldman made over 90 million inaccurate order memoranda, inaccurately reported over 6.8 million trades and overreported over 98,000 trades to a trade reporting facility, and issued over 372,000 inaccurate trade confirmations, in violation of Exchange Act § 17(a), Exchange Act Rule 17a-3, and

Election Notice - 5/15/2025

The annual meeting of FINRA firms will take place on or about August 18, 2025, to elect one Large Firm Governor and one Small Firm Governor to the FINRA Board of Governors (FINRA Board). A formal notice of the meeting, including the precise date, time and location, will be mailed to executive representatives on or about July 18, 2025.

23-02817(2).pdf

24-02313.pdf

2025 Cyber Crime Conference (C3)

Ben Feldmeyer Comment On Regulatory Notice 25-05

May 13, 2025

Ms. Jennifer Piorko Mitchell Office of the Corporate Secretary FINRA

1735 K Street

Washington, DC 20006

Re: Request for Commenton Regulatory Notice25-05

Dear Ms. Mitchell,

I am an owner of a Registered Investment Advisory firm and a registered representative of an unaffiliated FINRA member firm. I appreciate the opportunity to comment on the newly proposed Rule 3290 as set forth in FINRA Regulatory Notice 25-05.