2018059545201 3-20260 ROBERT JUAN ESCOBIO CRD 703813 SEC Opinion vw (2023-1689380403635).pdf
Richard Carlesco Comment On Regulatory Notice 23-11
Unintended Consequences I have been a long time critic of the net capital rule. The vast majority of FINRA Members (Not Subjects) are Introducing Broker Dealers. We spend thousands of dollars each year to maintain net capital and the audited financials that are required. If a introducing Broker Dealer goes under who is harmed? The client has their funds held in separate accounts and they get statements directly from those companies. The registered representatives can block transfer their accounts to a new firm. Who is harmed?