Brett A Gildner Comment On Regulatory Notice 21-19
Brett A Gildner
None
My investment experience has been limited to the last few years, so I can’t pretend to have a comprehensive understanding of every law, rule, guideline, parameter, and standard operating procedure that financial institutions operate in accordance with. However, I can say with certainty that neither do major financial institutions responsible for the behavior of our markets. If the role of a market maker is to provide liquidity for our markets, then a ‘failure to deliver’ directly conflicts with their core responsibilities. The goal of FINRA, in their own words, is “…protecting investors and safeguarding market integrity in a manner that facilitates vibrant capital markets.” The proposed rules in Regulatory Notice 21-19 satisfies these goals while simultaneously increasing confidence in market makers and illuminating dishonest practices of those found to be hiding potentially detrimental ‘fail to deliver’ data from investors. The actions of Wells Fargo & Co. in defrauding investors highlights the need for Regulatory Notice 21-19: In 2016, Wells Fargo & Co. were charged with giving investors deliberately incorrect information in an attempt to bolster revenue for themselves at the expense of their clients. It would be safe to assume that a $4 billion in fines (Reuters) would deter Wells Fargo & Co. from ever placing their interests before their investors’ again. You would be wrong. In 2020, Wells Fargo & Co. were charged with giving investors deliberately incorrect information in an attempt to bolster revenue for themselves at the expense of their clients. I’d like to draw attention to the fact that all I had to do was copy and paste the last sentence, changing only the year. Time and time again, financial institutions have sought to exploit one vulnerability: any area not subject to reporting to a financial regulatory agency. It is in this area that the most heinous of offenses and the most detrimental actions to our economy occurs, and it is for this such reason that Regulatory Notice 21-19 must be implemented. The proposed rule won’t fix our financial institutions, but it further narrows the scope of which these institutions may continue to behave irresponsibly without being held accountable.
Brett A Gildner Comment On Regulatory Notice 21-19
My investment experience has been limited to the last few years, so I can’t pretend to have a comprehensive understanding of every law, rule, guideline, parameter, and standard operating procedure that financial institutions operate in accordance with. However, I can say with certainty that neither do major financial institutions responsible for the behavior of our markets. If the role of a market maker is to provide liquidity for our markets, then a ‘failure to deliver’ directly conflicts with their core responsibilities. The goal of FINRA, in their own words, is “…protecting investors and safeguarding market integrity in a manner that facilitates vibrant capital markets.” The proposed rules in Regulatory Notice 21-19 satisfies these goals while simultaneously increasing confidence in market makers and illuminating dishonest practices of those found to be hiding potentially detrimental ‘fail to deliver’ data from investors. The actions of Wells Fargo & Co. in defrauding investors highlights the need for Regulatory Notice 21-19: In 2016, Wells Fargo & Co. were charged with giving investors deliberately incorrect information in an attempt to bolster revenue for themselves at the expense of their clients. It would be safe to assume that a $4 billion in fines (Reuters) would deter Wells Fargo & Co. from ever placing their interests before their investors’ again. You would be wrong. In 2020, Wells Fargo & Co. were charged with giving investors deliberately incorrect information in an attempt to bolster revenue for themselves at the expense of their clients. I’d like to draw attention to the fact that all I had to do was copy and paste the last sentence, changing only the year. Time and time again, financial institutions have sought to exploit one vulnerability: any area not subject to reporting to a financial regulatory agency. It is in this area that the most heinous of offenses and the most detrimental actions to our economy occurs, and it is for this such reason that Regulatory Notice 21-19 must be implemented. The proposed rule won’t fix our financial institutions, but it further narrows the scope of which these institutions may continue to behave irresponsibly without being held accountable.