Regulatory Notice 22-18
Summary
FINRA has received an increasing number of reports regarding registered representatives and associated persons (representatives) forging or falsifying customer signatures, and in some cases signatures of colleagues or supervisors, through third-party digital signature platforms. Firms have, for example, identified signature issues involving a wide range of forms, including account opening documents and updates, account activity letters, discretionary trading authorizations, wire instructions and internal firm documents related to the review of customer transactions.
2020067267701 Ernest Frerking CRD 2588177 AWC gg (2022-1662078023124).pdf
2021070774101 David Wilkie CRD 467130 AWC gg (2022-1662078021897).pdf
Matt Lynch Comment On Regulatory Notice 22-17
This rule would be almost impossible to adhere to for those in market making roles as the time it takes to book trades can take over 1 minute. If market makers need to pause trading responsibilities to book trades within the 1 minute time limit, this would actually cause bond markets to be less efficient.