Memo #
28170

ICI Draft Comment Letter in Response to FINRA's Rule 2210 BrokerCheck Proposal; Comments Requested by June 11
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[28170]

June 9, 2014

TO: INTERNAL SALES MANAGERS ROUNDTABLE No. 6-14
SALES FORCE MARKETING COMMITTEE No. 5-14 RE: ICI DRAFT COMMENT LETTER IN RESPONSE TO FINRA’S RULE 2210 BROKERCHECK PROPOSAL; COMMENTS REQUESTED BY JUNE 11

 

As previously reported, [1] FINRA is seeking comment on a revised proposal to require a reference and hyperlink to BrokerCheck [2] in certain of FINRA member firms’ online retail communications. [3]  More specifically, the Proposal would require a firm to include a readily apparent reference and hyperlink to BrokerCheck on each website that is available to retail investors and in online retail communications that include a professional profile of, or contact information for, an associated person, subject to specified conditions and exceptions.

Informed by feedback received from members during our call on May 16, ICI has prepared the attached draft comment letter, which supports the Proposal.  Our draft letter recommends that:

  • Under proposed Rule 2210(d)(8)(A), members be given flexibility to determine where on their websites the reference and hyperlink to BrokerCheck should be placed; and
  • Under proposed Rule 2210(d)(8)(C)(i), FINRA expand this exception to include other similar forms of messaging that may emerge in the future, in addition to electronic mail and text messages.

If members have any comments on the draft letter, please contact me at matt.thornton@ici.org or (202) 371-5406 by no later than Wednesday, June 11 (close of business). The deadline for submitting the comment letter is Monday, June 16.

 

Matthew Thornton
Assistant Counsel

Attachment

endnotes

[1] See Institute Memorandum No. 28108, dated May 9, 2014.

[2] FINRA’s BrokerCheck provides the public with information on the professional background, business practices, and conduct of FINRA member firms and their associated persons.

[3] FINRA Notice 14-19, “BrokerCheck” (April 2014) (the “Proposal”), available at: http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p496867.pdf.