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Paul Kienbaum Comment On Regulatory Notice 22-17

Paul Kienbaum

[OCS SUBMISSION] As Principal and owner of small BD in business for over 40 years....I believe, along with my FINOP Sally Mann, that the shortened time frame for reporting from 15 min to 1 minute is NOT reasonable. This change would create havoc, expenses, and non compliance for many BD's. We strongly suggest no change to this rule.