If I understand correctly that “Investment-related activity” means pertaining to financial assets, including securities, crypto assets, commodities, derivatives (such as futures and swaps), currency,
banking, real estate or insurance, this seems too broad.
If I understand that the proposal would also require B/D's to approve each transaction in writing for each representative, that seems to amplify the regulatory burden. It introduces vagueness,
increases compliance costs, threatens personal liberty, and undermines professional autonomy,
particularly for small firms and independent advisors.
FINRA should not move forward with this proposal in its current form. Instead, I urge FINRA to retain the current bifurcated structure under Rules 3270 and 3280, and, if warranted, issue updated guidance to clarify expectations without resorting to a new rule.
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Craig Ruffolo Comment On Regulatory Notice 25-05
I write in opposition to the proposal.
If I understand correctly that “Investment-related activity” means pertaining to financial assets, including securities, crypto assets, commodities, derivatives (such as futures and swaps), currency,
banking, real estate or insurance, this seems too broad.
If I understand that the proposal would also require B/D's to approve each transaction in writing for each representative, that seems to amplify the regulatory burden. It introduces vagueness,
increases compliance costs, threatens personal liberty, and undermines professional autonomy,
particularly for small firms and independent advisors.
FINRA should not move forward with this proposal in its current form. Instead, I urge FINRA to retain the current bifurcated structure under Rules 3270 and 3280, and, if warranted, issue updated guidance to clarify expectations without resorting to a new rule.