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.

2023077084701 Mariner Investment Group CRD 35993 AWC gg (2025-1744935599494).pdf

From June 2020 until December 2023, Mariner failed to establish and maintain a supervisory system, including written policies and procedures, reasonably designed to achieve compliance with Regulation Best Interest (Reg BI). In addition, the firm failed to identify or investigate a red flag associated with the purchase of a non-traditional exchange-traded product (NT-ETP). As a result, the firm willfully violated Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 and violated FINRA Rules 3110 and 2010.
Subscribe to