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Regulatory Notice 12-39

FINRA Requests Comment on TRACE Dissemination Issues

Due to the disruption of normal business operations relating to Hurricane Sandy, FINRA is extending the deadline to provide comment to November 19, 2012. (Previously, the deadline was extended to November 9, 2012.)

Comment Period Expires: November 19, 2012

Trade Reporting and Compliance Engine (TRACE)

Regulatory Notice
Notice Type

Request for Comment
Suggested Routing

Compliance
Fixed Income
Legal
Trading
Key Topics

Dissemination Caps
Rule 144A Transactions
TRACE Dissemination
TRACE-Eligible Security
Referenced Rules & Notices

FINRA Rule 6710
FINRA Rule 6750
Securities Act Section 3
Securities Act Section 5
Securities Act Rule 144A

Executive Summary

FINRA requests comment on two issues relating to the dissemination of information on TRACE-eligible securities transactions. First, FINRA seeks input on whether it should maintain or modify current TRACE dissemination caps, under which the actual size (volume) of a transaction over a certain par value is not displayed in disseminated real-time TRACE transaction data. Second, FINRA requests comment on whether transactions in TRACE-eligible securities effected pursuant to Securities Act Rule 144A1 (Rule 144A transactions) should be disseminated, and if so, the scope and manner of such dissemination.

Questions regarding this Notice should be directed to:

•    Elliot R. Levine, Associate Vice President and Counsel, Transparency Services, at (202) 728-8405; or
•    Sharon Zackula, Associate Vice President and Associate General Counsel, Office of General Counsel, at (202) 728-8985.

[On September 24, 2012 the comment period was extended from October 10, 2012 to November 9, 2012.]

Update on November 1, 2012: Due to the disruption of normal business operations relating to Hurricane Sandy, FINRA is extending the deadline to provide comment from November 9, 2012, to November 19, 2012

Action Requested

FINRA encourages all interested parties to comment on the proposal. Comments must be received by October 10, 2012.

Member firms and other interested parties can submit their comments using the following methods:

•  Emailing comments to [email protected]; or
•  Mailing comments in hard copy to:

Marcia E. Asquith
Office of the Corporate Secretary
FINRA
1735 K Street, N.W.
Washington, D.C. 20006-1506

To help FINRA process and review comments more efficiently, persons should only use one method to comment on the proposal.

Important Notes: The only comments FINRA will consider are those submitted using the methods described above. All comments received in response to this Notice will be made available to the public on the FINRA website. Generally, FINRA will post comments as they are received.2

Background & Discussion

Dissemination Caps

As part of the initial TRACE implementation in July 2002, FINRA established dissemination protocols that included certain caps. Disseminated TRACE transaction data includes price, time of execution, size and other information. The size disseminated is the total par value of the trade, subject to the limits of the applicable dissemination cap.

•  For investment grade TRACE-eligible securities and agency debt securities, the current dissemination cap is $5 million, and a transaction in excess of $5 million is disseminated as "$5MM+."3
•  For non-investment grade TRACE-eligible securities, the current dissemination cap is $1 million, and a transaction in excess of $1 million is disseminated as "$1MM+."4

FINRA recently announced additional caps as part of the dissemination of transaction information on agency pass-through mortgage-backed securities traded to be announced (TBA transactions).5 FINRA will begin disseminating TBA transactions on November 5, 2012.

•  For TBA transactions eligible "for good delivery," the dissemination cap is $25 million, and a transaction in excess of $25 million will be disseminated as "$25MM+."
•  For TBA transactions "not for good delivery," the dissemination cap is $10 million, and a transaction in excess of $10 million will be disseminated as "$10MM+."6

Discussion

FINRA periodically evaluates current practices and seeks input on modifications that may be beneficial. FINRA seeks comment as to whether to modify, leave unchanged or eliminate the $1 million and $5 million TRACE volume dissemination caps, which have been in place since TRACE began operating on July 1, 2002. As part of a broader effort to review dissemination practices, FINRA also seeks comment on the caps for TBA transactions that become effective on November 5, 2012.

Most firms have comprehensive policies and procedures for TRACE compliance, and regularly use TRACE data for pricing purposes, as well as for internal supervisory purposes. Providing transaction data showing the actual trade size may assist all market participants in determining the quality of their executions and member firms in complying with their best execution obligations. In addition, the dissemination of transaction data showing actual trade size may have a positive impact on the quality of pricing for valuation purposes.

The following tables show the percentage of transactions in TRACE-eligible securities reported to TRACE—excluding asset-backed securities—by total par value and trade count, that are effected at various sizes, and the impact of the $5 million dissemination cap (for investment grade and agency debt securities) and $1 million dissemination cap (for non-investment grade securities) on the percentage of par value and trades for which actual size is above the indicated cap level and therefore not displayed in disseminated data. The tables also show the impact of dissemination caps if set at alternative levels.7

INVESTMENT GRADE CORPORATE BONDS   NON-INVESTMENT GRADE CORPORATE BONDS   AGENCY DEBT SECURITIES
Percentage of Par Value Traded Above Cap Level Percentage of Par Value Traded Above Cap Level Percentage of Par Value Traded Above Cap Level
Cap Level Percentage Cap Level Percentage Cap Level Percentage
$1 million + 83.17% $1 million + Current Level 79.49% $1 million + 94.14%
$5 million + Current Level 48.91% $5 million + 36.39% $5 million + Current Level 77.20%
$10 million + 30.49% $10 million + 23.03% $10 million + 66.01%
$15 million + 22.99% $15 million + 18.39% $15 million + 60.07%
$20 million + 17.84% $20 million + 15.22% $20 million + 54.99%
$25 million + 14.10% $25 million + 12.89% $25 million + 47.42%
$50 million + 7.23% $50 million + 8.06% $50 million + 31.50%
$75 million + 5.19% $75 million + 6.59% $75 million + 26.93%
$100 million + 3.90% $100 million + 5.49% $100 million + 20.36%
Percentage of Trades Above Cap Level Percentage of Trades Above Cap Level Percentage of Trades Above Cap Level
Cap Level Percentage Cap Level Percentage Cap Level Percentage
$1 million + 8.08% $1 million + Current Level 10.85% $1 million + 23.90%
$5 million + Current Level 1.81% $5 million + 1.43% $5 million + Current Level 8.34%
$10 million + 0.64% $10 million + 0.46% $10 million + 4.65%
$15 million + 0.35% $15 million + 0.26% $15 million + 3.40%
$20 million + 0.21% $20 million + 0.16% $20 million + 2.64%
$25 million + 0.13% $25 million + 0.11% $25 million + 1.76%
$50 million + 0.03% $50 million + 0.03% $50 million + 0.63%
$75 million + 0.02% $75 million + 0.02% $75 million + 0.43%
$100 million + 0.0080% $100 million + 0.0105% $100 million + 0.23%

The following tables show the percentage of TBA transactions reported to TRACE, by total par value and trade count, that are effected at various sizes, and the impact the $25 million dissemination cap (for TBA transactions eligible "for good delivery") and the $10 million dissemination cap (for TBA transactions "not for good delivery") (based on historical transaction data) would have had on the percentage of par value traded and trades for which the actual size would not have been displayed (if such transactions had been disseminated during that period).8 The tables also show the impact of dissemination caps if set at alternative levels.

TBA GOOD DELIVERY TBA NOT GOOD DELIVERY
Percentage of Par Value Traded Above Cap Level Percentage of Par Value Traded Above Cap Level
Cap Level Percentage Cap Level Percentage
$10 million + 92.40% $10 million + Current Level 84.53%
$25 million + Current Level 84.17% $25 million + 54.71%
$50 million + 74.20% $50 million + 23.52%
$75 million + 69.37% $75 million + 15.50%
$100 million + 57.70% $100 million + 10.11%
$250 million + 33.82% $250 million + 2.68%
$500 million + 17.40% $500 million + 0.00%
Percentage of Trades Above Cap Level Percentage of Trades Above Cap Level
Cap Level Percentage Cap Level Percentage
$10 million + 32.79% $10 million + Current Level 41.47%
$25 million + Current Level 20.13% $25 million + 15.98%
$50 million + 12.45% $50 million + 3.80%
$75 million + 10.04% $75 million + 1.80%
$100 million + 6.19% $100 million + 0.90%
$250 million + 1.87% $250 million + 0.12%
$500 million + 0.51% $500 million + 0.00%

Rule 144A Transactions

Securities Act Rule 144A is a safe harbor exemption from the registration requirements of Securities Act Section 5 for certain offers and sales of qualifying securities by certain persons other than the issuer of the securities. The exemption applies to the re-sale of securities to qualified institutional buyers (QIBs).9 Rule 144A transactions have been subject to TRACE reporting requirements since TRACE inception. Unlike transactions in publicly traded bonds, Rule 144A transactions are not subject to dissemination because of the private nature of the transactions.10 However, this approach results in limited or no price transparency in the market in Rule144A TRACE-eligible securities. Without any disseminated data, it may be difficult for market participants to assess the quality of the executions of their orders and for firms to determine if they have complied with their best execution obligations. In addition, the lack of disseminated data in Rule 144A transactions may have an adverse impact on the accurate valuation of positions in such securities.

FINRA seeks comment on the current approach and whether Rule 144A transactions should be subject to dissemination. FINRA notes that Rule 144A transactions account for approximately 4 percent of trades and 18 percent of par value in corporate debt securities reported to TRACE. The table below summarizes the percentage of all TRACE corporate debt trades, all TRACE non-investment grade corporate debt trades and all TRACE investment grade corporate debt trades that are Rule 144A trades.11

  July 2011 Through June 2012
Rule 144A trades as a percentage of total TRACE corporate trades 4.37%
Rule 144A non-investment grade trades as a percentage of all TRACE non-investment grade trades 8.09%
Rule 144A investment grade trades as a percentage of all TRACE investment grade corporate trades 2.50%
Rule 144A par value traded as a percentage of total TRACE corporate par value traded 17.53%
Rule 144A non-investment grade par value traded as a percentage of all TRACE non-investment grade corporate par value traded 20.59%
Rule 144A investment grade par value traded as a percentage of all TRACE investment grade corporate par value traded 14.89%

If Rule 144A transactions were disseminated and dissemination caps were applied, the following tables show the percentages of Rule 144A transactions (and par value traded) that would be subject to various dissemination cap levels.

July 2011 Through June 2012 July 2011 Through June 2012
INVESTMENT GRADE RULE 144A NON-INVESTMENT GRADE RULE 144A
Percentage of Par Value Traded Above Cap Level Percentage of Par Value Traded Above Cap Level
Cap Level Percentage Cap Level Percentage
$1 million + 94.02% $1 million + 89.41%
$5 million + 64.30% $5 million + 44.63%
$10 million + 47.22% $10 million + 30.57%
$15 million + 39.48% $15 million + 25.07%
$20 million + 33.58% $20 million + 21.20%
$25 million + 28.40% $25 million + 18.42%
$50 million + 18.01% $50 million + 12.22%
$75 million + 14.70% $75 million + 9.93%
$100 million + 12.48% $100 million + 8.01%
Percentage of Trades Above Cap Level Percentage of Trades Above Cap Level
Cap Level Percentage Cap Level Percentage
$1 million + 50.68% $1 million + 51.47%
$5 million + 13.28% $5 million + 7.35%
$10 million + 5.52% $10 million + 2.61%
$15 million + 3.38% $15 million + 1.51%
$20 million + 2.23% $20 million + 0.96%
$25 million + 1.44% $25 million + 0.66%
$50 million + 0.42% $50 million + 0.21%
$75 million + 0.23% $75 million + 0.12%
$100 million + 0.15% $100 million + 0.06%

Request for Comment

FINRA welcomes all comments on the use of dissemination caps and the dissemination of Rule 144A transactions. FINRA also specifically requests comment on the issues identified below.

Dissemination Caps for Investment Grade and Non-Investment Grade Debt Securities

1. What would be the impact of raising the dissemination caps for:
a. investment grade TRACE-eligible securities transactions to $10 million, $15 million, $20 million or higher; and
b. non-investment grade TRACE-eligible securities transactions to $5 million, $10 million, $20 million or higher?
2. Should FINRA set a dissemination cap applicable solely to agency debt securities in light of the larger size of many transactions in such securities?
a. If so, should it be set at $25 million, $50 million, $100 million or higher?
3. Should there continue to be different dissemination caps for investment grade and non-investment grade debt securities?
4. Should the dissemination caps for investment grade and non-investment grade debt securities be eliminated entirely?
5. Would the information available as a result of higher dissemination caps allow broker-dealers and institutional investors to better value positions?
6. Could alternative ways of determining dissemination caps—for example, by dollar value12 of transaction rather than par value—provide meaningful trade volume exposure while still limiting the transaction sizes displayed through the caps?

Dissemination Caps for TBA Transactions

1. Should there be a dissemination cap for TBA transactions?
a. If yes, are the levels appropriate or should higher or lower caps be considered?

Rule 144A Transactions

1. Should Rule 144A transactions-private re-sales of securities to QIBs-be subject to dissemination?
2. If yes, should Rule 144A transactions be subject to dissemination in the same manner as other disseminated transactions in TRACE-eligible securities?
a. If yes, should they be disseminated subject to a dissemination cap?
b. If yes, what is the appropriate size (volume) at which to set the dissemination cap?
c. If yes, should FINRA distinguish between investment grade and non-investment grade securities, and set a higher dissemination cap for Rule 144A transactions in investment grade securities and a lower dissemination cap for Rule 144A transactions in non-investment grade securities?
3. Would dissemination of Rule 144A transaction information impact investment decisions and price negotiations, and, if yes, how?
4. If information on Rule 144A TRACE-eligible securities transactions should be disseminated, should the transaction information be disseminated publicly without limitation or on a more limited basis?

1 17 CFR 239.144A.

2 FINRA will not edit personal identifying information, such as names or email addresses, from submissions. Persons should submit only information that they wish to make publicly available. See Notice to Members 03-73 (November 2003) (NASD Announces Online Availability of Comments) for more information.

3 The term investment grade is defined in FINRA Rule 6710(h). In most cases, an agency debt security that is not rated is traded and priced as an investment grade security. Thus, for purposes of TRACE, in most cases, such securities are classified as investment grade debt and subject to the $BMM+ dissemination cap. The term agency debt security is defined in FINRA Rule 6710(1).

4 The term non-investment grade is defined in FINRA Rule 6710(i). For purposes of TRACE, most unrated corporate bonds are considered non-investment grade debt and are subject to the $1MM+ dissemination cap.

5 The terms agency pass-through mortgage-backed security and to be announced are defined in, respectively, FINRA Rule 6710(v) and FINRA Rule 6710(u). See Securities Exchange Act Release No. 66829 (April 18, 2012), 77 FR 24748 (April 25, 2012) (SEC Approval Order Relating to Post-Trade Transparency of Agency Pass-Through Mortgage-Backed Securities Traded TBA) (TBA Dissemination Approval Order); Regulatory Notice 12-26 (May 2012) (announcing November 5, 2012, as the effective date for the dissemination of TBA transactions, dissemination caps for such TBA transactions, and related rule changes).

6See FINRA Rule 6710(u) (as effective on November 5, 2012) for reference to the terms "for good delivery" and "not for good delivery." See also Regulatory Notice 12-26 and TBA Dissemination Approval Order.

7 FINRA calculated the percentages based on the 12-month period from July 1, 2011, to June 30, 2012.

8See supra note 5.

9 Qualified institutional buyer is defined in Securities Act Rule 144A(a)(1). 17 CFR 239.144A(a)(1).

10See FINRA Rule 6750(b)(1).

11 FINRA calculated the percentages based on the 12-month period from July 1, 2011, to June 30, 2012.

12 For this discussion, the dollar value of the transaction means the par value multiplied by the execution price of the transaction.

The views, expressions, findings and opinions expressed in the comments on this Web page are solely those of the author(s) and FINRA accepts no responsibility for the content of the comments:
Date Commenter
Income Research & Management Comments on Regulatory Notice 12-39
Mesirow Financial, Inc. Comments on Regulatory Notice 12-39
Michael D’Angelo Comments on Regulatory Notice 12-39
Benchmark Solutions, Inc. Comments on Regulatory Notice 12-39
The Nelson Law Firm, LLC Comments on Regulatory Notice 12-39
Dimensional Fund Advisors LP Comments on Regulatory Notice 12-39
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The Credit Roundtable Comments on Regulatory Notice 12-39
BAM Advisor Services Comments on Regulatory Notice 12-39
Portfolio Advisors, Inc. Comments on Regulatory Notice 12-39
Bristlecone Advisors, LLC Comments on Regulatory Notice 12-39
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Strategic Wealth Management Comments on Regulatory Notice 12-39
Boardwalk Financial Strategies LLC Comments on Regulatory Notice 12-39
Jeff Buckner Comments on Regulatory Notice 12-39
Guy Baker Comments on Regulatory Notice 12-39
Dale K. Ehrhart Inc. Comments on Regulatory Notice 12-39
Matson Money, Inc. Comments on Regulatory Notice 12-39
Jeff Holland Comments on Regulatory Notice 12-39
Robert Piano Comments on Regulatory Notice 12-39
Nevils Financial, LLC Comments on Regulatory Notice 12-39
Gary Pia Comments on Regulatory Notice 12-39
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Vickery Financial Services, Inc. Comments on Regulatory Notice 12-39
Integral Financial Solutions, LLC Comments on Regulatory Notice 12-39
DKE, Inc. Comments on Regulatory Notice 12-39
FMB Wealth Management and FMB Retirement Services Comments on Regulatory Notice 12-39
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Provizio Global Advisors Inc. Comments on Regulatory Notice 12-39
Quality Asset Management Comments on Regulatory Notice 12-39
Willow Creek Financial Services, Inc. Comments on Regulatory Notice 12-39
Cypress Partners Comments on Regulatory Notice 12-39
Dean Roland Russell Comments on Regulatory Notice 12-39
Disciplined Equity Management, Inc. Comments on Regulatory Notice 12-39
Northgate Wealth Management Comments on Regulatory Notice 12-39
McGladrey Wealth Management LLC Comments on Regulatory Notice 12-39
Brown Wealth Management, LLC Comments on Regulatory Notice 12-39
Redrock Wealth Management, LLC Comments on Regulatory Notice 12-39
Beacon Financial Planning, LLC Comments on Regulatory Notice 12-39
Haymarket Wealth Management Comments on Regulatory Notice 12-39
Carrington Financial Planning, LLC Comments on Regulatory Notice 12-39
Critical Capital Management, Inc. Comments on Regulatory Notice 12-39ce 12-39
Structured Asset Management, Inc. Comments on Regulatory Notice 12-39
Hankinson Wealth Management, Inc. Comments on Regulatory Notice 12-39
Gasber Financial Advisors, Inc. Comments on Regulatory Notice 12-39
LifeFocus Financial Advisors, LLC Comments on Regulatory Notice 12-39
Mariaca Wealth Management, LLC Comments on Regulatory Notice 12-39
John Jackson Comments on Regulatory Notice 12-39
Carolyn Lloyd-Cohen LLC/Preferred Pensions LLC Comments on Regulatory Notice 12-39
Sandy Burnham Comments on Regulatory Notice 12-39
McGladrey Wealth Management LLC Comments on Regulatory Notice 12-39
Sequent Asset Management, LLC Comments on Regulatory Notice 12-39
Skaggs Financial Planning, LLC Comments on Regulatory Notice 12-39
Daly Investment Management, LLC Comments on Regulatory Notice 12-39
Alliant Wealth Advisors Comments on Regulatory Notice 12-39
Resource Consulting Group Comments on Regulatory Notice 12-39
Compass Financial Group, Inc. Comments on Regulatory Notice 12-39
Investment Advisory Professionals, LLC Comments on Regulatory Notice 12-39
Global Wealth Advisors LLC Comments on Regulatory Notice 12-39
The First National Bank in Sioux Falls Comments on Regulatory Notice 12-39
Lamia Fiancial Group, LLC Comments on Regulatory Notice 12-39
TAGStone Capital, Inc. Comments on Regulatory Notice 12-39
Berkson Asset Management Comments on Regulatory Notice 12-39
Strategic Investment Advisors, LLC Comments on Regulatory Notice 12-39
Adam Hoffmann Comments on Regulatory Notice 12-39
DRV Group, Inc. Comments on Regulatory Notice 12-39
The Wealth Conservatory Comments on Regulatory Notice 12-39
Greenberg/Graham Advisors LLC Comments on Regulatory Notice 12-39
Horizon Asset Management, LLC Comments on Regulatory Notice 12-39
Hollingsworth Avent Averre & Purvis, PA Comments on Regulatory Notice 12-39
John A. Wolfe & Associates, Inc. Comments on Regulatory Notice 12-39
Life Planning Partners, Inc. Comments on Regulatory Notice 12-39
Portland Fixed Income Specialists, LLC Comments on Regulatory Notice 12-39
Paragon Wealth Strategies, LLC Comments on Regulatory Notice 12-39
Stanley F. Green, LLC Comments on Regulatory Notice 12-39
1650 Wealth Management Comments on Regulatory Notice 12-39
LSY Financial Group Comments on Regulatory Notice 12-39
Daniel. G Gensler Comments on Regulatory Notice 12-39
Horizon Asset Management, LLC Comments on Regulatory Notice 12-39
Horizon Wealth Management Comments on Regulatory Notice 12-39
The Wealth Conservatory Comments on Regulatory Notice 12-39
Financial Advisory Corporation Comments on Regulatory Notice 12-39
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AHC Advisors, Inc. Comments on Regulatory Notice 12-39
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LPL Financial Advisor Comments on Regulatory Notice 12-39
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Johnson Wealth Management, LLC Comments on Regulatory Notice 12-39
Investment Company Institute Comments on Regulatory Notice 12-39
Lakeside Wealth Management Comments on Regulatory Notice 12-39
Frederick Capital Management, Inc. Comments on Regulatory Notice 12-39
Acropolis Investment Management, LLC. Comments on Regulatory Notice 12-39
GB&T Financial Services Comments on Regulatory Notice 12-39
Brian Caine Comments on Regulatory Notice 12-39
True Wealth Design, LLC Comments on Regulatory Notice 12-39
The Cogent Advisor Comments on Regulatory Notice 12-39
Scott Stuth Comments on Regulatory Notice 12-39
Rowling & Associates Comments on Regulatory Notice 12-39
Prime Capital Equities Comments on Regulatory Notice 12-39
The Capital Group Comments on Regulatory Notice 12-39
Clune & Associates Ltd. Comments on Regulatory Notice 12-39
Del Monte Group, LLC Comments on Regulatory Notice 12-39
Pacesetter Financial Group, LLC Comments on Regulatory Notice 12-39
Moler Capital Management Comments on Regulatory Notice 12-39
SYM Financial Advisors Comments on Regulatory Notice 12-39
Investor’s Capital Management, LLC Comments on Regulatory Notice 12-39
Smart Choice Financial Planning, Inc. Comments on Regulatory Notice 12-39
The Humphreys Group Comments on Regulatory Notice 12-39
Strategic Investment Solutions, Inc. Comments on Regulatory Notice 12-39
Lighthouse Financial Planning, LLC Comments on Regulatory Notice 12-39
Mark Smith Financial Services Comments on Regulatory Notice 12-39
Dorman Advisory Services Comments on Regulatory Notice 12-39
Bob Neiman Comments on Regulatory Notice 12-39
Don Humphreys Comments on Regulatory Notice 12-39
SJS Investment Consulting, Inc. Comments on Regulatory Notice 12-39
Lawrence Johnson Comments on Regulatory Notice 12-39
Bank of Marin Comments on Regulatory Notice 12-39
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Maas Capital Advisors, LLC Comments on Regulatory Notice 12-39
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Index Portfolio Tools Advisors Comments on Regulatory Notice 12-39
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Wealth Management Group LLP CPA'S Comments on Regulatory Notice 12-39
Fifth Set Investment Advisors LLC Comments on Regulatory Notice 12-39
Maci Capital Advisors Comments on Regulatory Notice 12-39
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Conservative Wealth Management LLC Comments on Regulatory Notice 12-39
Structured Investment Advisors, LLC Comments on Regulatory Notice 12-39
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Independence Advisors, LLC Comments on Regulatory Notice 12-39
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Jeff Jaworski Comments on Regulatory Notice 12-39
Oak Wealth Advisors LLC Comments on Regulatory Notice 12-39
Gonzales & Sisto, LLP Comments on Regulatory Notice 12-39
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Chamberlain Financial Comments on Regulatory Notice 12-39
Porter, White & Company Comments on Regulatory Notice 12-39
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Life Planning Partners, Inc. Comments on Regulatory Notice 12-39
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Onyx Financial Advisors Comments on Regulatory Notice 12-39
Quilici Asset Management Comments on Regulatory Notice 12-39
Vista Capital Partners Comments on Regulatory Notice 12-39
Premier Financial Group Comments on Regulatory Notice 12-39
KAI Advisors Comments on Regulatory Notice 12-39
Tomlin Financial Advisors, Inc. Comments on Regulatory Notice 12-39
Keats Connelly Comments on Regulatory Notice 12-39
Mercer Advisors Comments on Regulatory Notice 12-39
GenSpring Family Offices, LLC Comments on Regulatory Notice 12-39
Ken Ransford Comments on Regulatory Notice 12-39
Compass Investments Comments on Regulatory Notice 12-39
Wealth Advisors, Inc. Comments on Regulatory Notice 12-39
Retirement Asset Management Comments on Regulatory Notice 12-39
Rall Capital Management Comments on Regulatory Notice 12-39
Vista Capital Partners Comments on Regulatory Notice 12-39
JGHeller Private Wealth Advisors Comments on Regulatory Notice 12-39
Haton Consulting, Inc. Comments on Regulatory Notice 12-39
George N. Ellis Comments on Regulatory Notice 12-39
The Leonard Financial Group, LLC Comments on Regulatory Notice 12-39
Crestone Financial Advisors Comments on Regulatory Notice 12-39
Private Ocean Comments on Regulatory Notice 12-39
Northern Trust Comments on Regulatory Notice 12-39
SYM Financial Advisors Comments on Regulatory Notice 12-39
Efficient Frontier Advisors LLC Comments on Regulatory Notice 12-39
North Ridge Wealth Advisors, Inc. Comments on Regulatory Notice 12-39
Michael D. Strasser Comments on Regulatory Notice 12-39
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TCM Wealth Management, LLC Comments on Regulatory Notice 12-39
Silver Oak Advisory Group Comments on Regulatory Notice 12-39
Millard & Company, Inc. Comments on Regulatory Notice 12-39
Bond & Co. Comments on Regulatory Notice 12-39
Bergland Wealth Management, Inc. Comments on Regulatory Notice 12-39
Delphi Private Advisors Comments on Regulatory Notice 12-39
Cambridge Wealth Counsel Comments on Regulatory Notice 12-39
GenSpring Family Office Comments on Regulatory Notice 12-39
Wendell Miller Comments on Regulatory Notice 12-39
M Financial Group Comments on Regulatory Notice 12-39e 12-39
AZ Wealth Strategies, LLC Comments on Regulatory Notice 12-39
Michael Broad Comments on Regulatory Notice 12-39
Pacific Asset Management Comments on Regulatory Notice 12-39
Focus Wealth Management, Ltd. Comments on Regulatory Notice 12-39
Stonegate Financial Group Comments on Regulatory Notice 12-39
Servo Wealth Management Comments on Regulatory Notice 12-39
Northstar Financial Planning, Inc. Comments on Regulatory Notice 12-39
Titanium Advisors, LLC Comments on Regulatory Notice 12-39
Young Wealth Management Comments on Regulatory Notice 12-39
Brighton Jones, LLC Comments on Regulatory Notice 12-39
Berk Cleveland Rathmell Wealth Strategies, LLC Comments on Regulatory Notice 12-39
Delphi Private Advisors Comments on Regulatory Notice 12-39
CLS Financial Advisors, Inc. Comments on Regulatory Notice 12-39
Integra Wealth, LLC Comments on Regulatory Notice 12-39
Jameson Van Houten Comments on Regulatory Notice 12-39
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Cadence Wealth Management Comments on Regulatory Notice 12-39
Sechrest Financial Services, LLC Comments on Regulatory Notice 12-39
Rather & Kittrell Comments on Regulatory Notice 12-39
Lourd Capital Management Comments on Regulatory Notice 12-39
The Lam Group, Inc. Comments on Regulatory Notice 12-39
Thomas Financial Group Comments on Regulatory Notice 12-39
Pacific Asset Management, LLC Comments on Regulatory Notice 12-39
William Bernstein Comments on Regulatory Notice 12-39
Assabet Advisors, LLC Comments on Regulatory Notice 12-39
Claris Advisors Comments on Regulatory Notice 12-39
Bromfield Financial Advisory Group, Inc. Comments on Regulatory Notice 12-39
Foster Wealth Comments on Regulatory Notice 12-39
Coston and McIsaac Investment Advisers, LLC Comments on Regulatory Notice 12-39
Kibble & Prentice Private Client Services Comments on Regulatory Notice 12-39
Merriman Comments on Regulatory Notice 12-39
Michael D. Taxman Investment Management Comments on Regulatory Notice 12-39
D’Orazio & Associates, Inc. Comments on Regulatory Notice 12-39
Stoker Ostler Wealth Advisors, Inc. Comments on Regulatory Notice 12-39
Sensenig Capital Advisors Comments on Regulatory Notice 12-39
Marian P. Young Comments on Regulatory Notice 12-39
The Proper Analysis Corporation Comments on Regulatory Notice 12-39
Thalheimer Financial Planning Comments on Regulatory Notice 12-39
Talis Advisors Comments on Regulatory Notice 12-39
Prudent Man Investment Management, Inc. Comments on Regulatory Notice 12-39
Colin Wiens Financial Advisor, Larson Financial Comments on Regulatory Notice 12-39
Passive Capital Management Comments on Regulatory Notice 12-39
The Legacy Financial Group, Inc. Comments on Regulatory Notice 12-39
Tom Posey Comments on Regulatory Notice 12-39
1926 Investment Advisors, LLC Comments on Regulatory Notice 12-39
Index Funds Advisors, Inc. Comments on Regulatory Notice 12-39
Bromfield Financial Advisory Group, Inc. Comments on Regulatory Notice 12-39
Wealth Management, LLC Comments on Regulatory Notice 12-39
Symmetry Partners, LLC Comments on Regulatory Notice 12-39
Van Sant & Mewshaw Inc. Comments on Regulatory Notice 12-39
Yellowstone Financial, Inc. Comments on Regulatory Notice 12-39
Beacon Financial Advisers, Inc. Comments on Regulatory Notice 12-39
The Planning Center, Inc. Comments on Regulatory Notice 12-39
SIFMA Comments on Regulatory Notice 12-39
Denver Money Manager, LLC Comments on Regulatory Notice 12-39
Financial Plan, Inc. Comments on Regulatory Notice 12-39
TCI Wealth Advisors, Inc. Comments on Regulatory Notice 12-39
Savant Capital Management Comments on Regulatory Notice 12-39
Lifeline Financial, LLC Comments on Regulatory Notice 12-39
Beaird Harris Wealth Management, Inc. Comments on Regulatory Notice 12-39
Glass Jacobson Investment Advisors, LLC Comments on Regulatory Notice 12-39
Renaissance Wealth Counsel, LLC Comments on Regulatory Notice 12-39
BAM Advisor Services Comments on Regulatory Notice 12-39
Johnson Financial Group Comments on Regulatory Notice 12-39
Southeast Financial Planning & Consulting Inc Comments on Regulatory Notice 12-39
REDW Stanley Financial Advisors LLC Comments on Regulatory Notice 12-39
Pathways Financial Partners Comments on Regulatory Notice 12-39
Sanctuary Wealth Management LLC Comments on Regulatory Notice 12-39
Sechrest & Bloom, LLC/Sechrest Financial Services, LLC Comments on Regulatory Notice 12-39
The Legacy Financial Group, Inc. Comments on Regulatory Notice 12-39
Interactive Data Corporation Comments on Regulatory Notice 12-39
Sherrill Wealth Management Comments on Regulatory Notice 12-39
Aequitas Investment Advisors, LLC Comments on Regulatory Notice 12-39
Trellis Wealth Advisors Comments on Regulatory Notice 12-39
McCartney Wealth Management LLC Comments on Regulatory Notice 12-39
Bond Dealers of America Comments on Regulatory Notice 12-39
Coastal Securities Comments on Regulatory Notice 12-39
Robert Bove Comments on Regulatory Notice 12-39
Principia Investment Advisors LLC Comments on Regulatory Notice 12-39
Guardian Wealth Management, Inc. Comments on Regulatory Notice 12-39
Wagner Wealth Management Comments on Regulatory Notice 12-39
Bergland Wealth Management Comments on Regulatory Notice 12-39
Ellis Capital Management Comments on Regulatory Notice 12-39
Mercer Advisors Inc. Comments on Regulatory Notice 12-39
Brighton Jones, LLC Comments on Regulatory Notice 12-39
Clifford E. Fowler, Jr. Comments on Regulatory Notice 12-39
The Bishoff Financial Group Comments on Regulatory Notice 12-39
CCP Financial Planning Services, Inc. Comments on Regulatory Notice 12-39
Mercer Advisors Comments on Regulatory Notice 12-39
Global Wealth Management Inc. Comments on Regulatory Notice 12-39
Hines Warner Wealth Management Comments on Regulatory Notice 12-39
Larson Financial Group Comments on Regulatory Notice 12-39
Focus Wealth Management Comments on Regulatory Notice 12-39
SK Wealth Management, L.L.C. Comments on Regulatory Notice 12-39
Bob Luxenberg Comments on Regulatory Notice 12-39