Revise cybersecurity deficiency fines and penalties program. Applying both monetary fines and remedial actions deplete capital available for infrastructure improvements. Instead, negotiate remedial action plan and cost allocations for dedicated investment in their cybersecurity program along with accountability. The fine money has been counterproductive to firms directly improving their firm and investor protection capabilities.

Rule 17a-5 requires all member firms to file Schedule 1 of Form X-17A-5. This Schedule is a calendar year--end report filed by all registrants as a supplement to the regular fourth quarter FOCUS report. Schedule 1 requires the reporting of general information designed to measure certain economic and financial characteristics of the registrant. I believe this form is redundant, requesting information that is already available on the Firm’s FINRA Gateway Profile (# of RRs, # of branches