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Janice Parise Comment On Regulatory Notice 25-05

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), FOCUS report, and Form Custody. I think Schedule 1 should be eliminated as a requirem

Epperson & Greenidge PA Comment On Regulatory Notice 25-07

FINRA should change FINRA Rules 12402 and 12403 so that all Claimants and all Respondents have to share the same number of strikes when ranking arbitrators. Under the current rule so long as a brokerage firm and the financial advisor are represented by different law firms then they would get twice as many strikes as a group of investors who are represented by the same law firm.  In criminal court all defendants have to share strikes for jury selection. It should be the same in FINRA arbitrations.

Cresap Inc. Comment On Regulatory Notice 25-06

Many in the small firm community believe that it is not the rules that are the problem, but how they are enforced. FINRA seems to devote too much time and too many resources examining well-intentioned firms that are devoid of customer complaints, and whose behavior is unlikely to cause customer harm. FINRA struggles to apply metrics to firms in determining how to deploy regulatory efforts. Here are some simple suggestions: