Timothy Githens Comment On Regulatory Notice 25-05
Timothy Githens
Thank you for the opportunity to comment on Regulatory Notice 25-05. While I support efforts to streamline oversight, I oppose the proposed consolidation of Rules 3270 and 3280 in their current form.
The definition of "investment-related activities" is overly broad and risks encompassing low-risk or personal activities that do not warrant regulatory scrutiny. This may overwhelm firms with unnecessary reporting while distracting from truly material conflicts.
Additionally, the proposal could create inconsistent burdens for dual-registered individuals and introduce privacy concerns by requiring disclosures that may conflict with client confidentiality.
Rather than reducing burdens, this rule may increase compliance costs and uncertainty. I urge FINRA to reconsider this approach and work more closely with stakeholders to craft a rule that is effective but reasonable.
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Timothy Githens Comment On Regulatory Notice 25-05
Thank you for the opportunity to comment on Regulatory Notice 25-05. While I support efforts to streamline oversight, I oppose the proposed consolidation of Rules 3270 and 3280 in their current form.
The definition of "investment-related activities" is overly broad and risks encompassing low-risk or personal activities that do not warrant regulatory scrutiny. This may overwhelm firms with unnecessary reporting while distracting from truly material conflicts.
Additionally, the proposal could create inconsistent burdens for dual-registered individuals and introduce privacy concerns by requiring disclosures that may conflict with client confidentiality.
Rather than reducing burdens, this rule may increase compliance costs and uncertainty. I urge FINRA to reconsider this approach and work more closely with stakeholders to craft a rule that is effective but reasonable.
Sincerely,
Timothy Githens