As a fully licensed financial professional and manager with Series 7, 66, 9, 10, and 31 registrations, I am writing to express strong opposition to Proposed Rule 3290 under FINRA Regulatory Notice 25-05. While I respect FINRA’s mission to ensure ethical conduct in our industry, this proposed rule would impose disproportionate restrictions on personal freedom, privacy, and professional autonomy—particularly regarding investments in digital assets.
The requirement that financial advisors obtain written broker-dealer approval before investing in any crypto asset—including extending this rule to spouses, partners, and household members—is overly invasive. It imposes a level of surveillance into personal financial choices that is not only unnecessary, but potentially damaging to the trust and independence we work so hard to maintain in our households and professional environments.
Additionally, this rule introduces severe operational challenges. Broker-dealers are not uniformly equipped to evaluate or manage personal crypto investment requests in real time. Unlike traditional securities, the digital asset market operates 24/7, with price volatility and liquidity windows that require timely, agile decision-making. By mandating prior written approval, the proposed rule could force financial professionals to miss critical entry or exit points—creating real financial risk through delay. In effect, it penalizes licensed professionals for responsibly participating in an emerging asset class.
From a risk-management standpoint, the rule conflates personal investment activity with outside business activity, which are two distinct matters. Advisors investing their own post-tax capital in widely available, non-proprietary assets for educational or long-term purposes should not be subject to pre-clearance requirements designed for conflict-prone activities.
In summary, while transparency is vital, this proposal overreaches. It compromises personal and familial privacy, disrupts firm operations, and introduces timing risk that is uniquely problematic in a 24/7 real-time market like crypto. I strongly urge FINRA to revise or reconsider this rule in favor of a more balanced, targeted approach that addresses legitimate regulatory concerns without inhibiting the financial freedom or market access of its own members.
Thank you for your time and consideration during this important comment period.
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Desiree Moreno Pineyro Comment On Regulatory Notice 25-05
Re: Comment on FINRA Regulatory Notice 25-05 – Proposed Rule 3290
Submitted by: Desiree Moreno Pineyro
Date:05/05/2025
To:
Jennifer Piorko Mitchell
Office of the Corporate Secretary
Financial Industry Regulatory Authority (FINRA)
1700 K Street, NW
Washington, DC 20006
Dear Ms. Mitchell,
As a fully licensed financial professional and manager with Series 7, 66, 9, 10, and 31 registrations, I am writing to express strong opposition to Proposed Rule 3290 under FINRA Regulatory Notice 25-05. While I respect FINRA’s mission to ensure ethical conduct in our industry, this proposed rule would impose disproportionate restrictions on personal freedom, privacy, and professional autonomy—particularly regarding investments in digital assets.
The requirement that financial advisors obtain written broker-dealer approval before investing in any crypto asset—including extending this rule to spouses, partners, and household members—is overly invasive. It imposes a level of surveillance into personal financial choices that is not only unnecessary, but potentially damaging to the trust and independence we work so hard to maintain in our households and professional environments.
Additionally, this rule introduces severe operational challenges. Broker-dealers are not uniformly equipped to evaluate or manage personal crypto investment requests in real time. Unlike traditional securities, the digital asset market operates 24/7, with price volatility and liquidity windows that require timely, agile decision-making. By mandating prior written approval, the proposed rule could force financial professionals to miss critical entry or exit points—creating real financial risk through delay. In effect, it penalizes licensed professionals for responsibly participating in an emerging asset class.
From a risk-management standpoint, the rule conflates personal investment activity with outside business activity, which are two distinct matters. Advisors investing their own post-tax capital in widely available, non-proprietary assets for educational or long-term purposes should not be subject to pre-clearance requirements designed for conflict-prone activities.
In summary, while transparency is vital, this proposal overreaches. It compromises personal and familial privacy, disrupts firm operations, and introduces timing risk that is uniquely problematic in a 24/7 real-time market like crypto. I strongly urge FINRA to revise or reconsider this rule in favor of a more balanced, targeted approach that addresses legitimate regulatory concerns without inhibiting the financial freedom or market access of its own members.
Thank you for your time and consideration during this important comment period.
Sincerely,
Desiree Moreno Pineyro
[LinkedIn: www.linkedin.com/in/desireemoreno]