I support FINRA's effort to modernize Rule 2210 and adopt a more risk-based supervisory framework for retail communications.
In my experience reviewing communications, the current rule often requires the same level of review for communications that present significantly different levels of investor risk. A risk-based approach would allow firms to focus supervisory resources on higher-risk communications, such as those involving recommendations, performance information, complex products, or promotional claims, while maintaining appropriate oversight of lower-risk communications.
This approach is particularly important given the growing volume of digital communications, social media content, and technology-assisted content creation. Modern supervisory frameworks should continue to promote investor protection while providing firms with flexibility to allocate review resources where they will have the greatest compliance and investor-protection benefit.
I believe the proposal appropriately preserves firms' supervisory obligations while recognizing that not all retail communications present the same level of regulatory risk. I encourage FINRA to continue pursuing a principles-based, risk-focused framework that emphasizes fair, balanced, and non-misleading communications rather than a uniform pre-use review requirement for all content.
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Sean Mannello Comment On Regulatory Notice 26-14
Hello,
I support FINRA's effort to modernize Rule 2210 and adopt a more risk-based supervisory framework for retail communications.
In my experience reviewing communications, the current rule often requires the same level of review for communications that present significantly different levels of investor risk. A risk-based approach would allow firms to focus supervisory resources on higher-risk communications, such as those involving recommendations, performance information, complex products, or promotional claims, while maintaining appropriate oversight of lower-risk communications.
This approach is particularly important given the growing volume of digital communications, social media content, and technology-assisted content creation. Modern supervisory frameworks should continue to promote investor protection while providing firms with flexibility to allocate review resources where they will have the greatest compliance and investor-protection benefit.
I believe the proposal appropriately preserves firms' supervisory obligations while recognizing that not all retail communications present the same level of regulatory risk. I encourage FINRA to continue pursuing a principles-based, risk-focused framework that emphasizes fair, balanced, and non-misleading communications rather than a uniform pre-use review requirement for all content.
Thank you for the opportunity to comment.
Sean Mannello
Senior Advertising Supervision Principal
Osaic