Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving a Proposed Rule Change Relating to Availability of Information Pursuant to FINRA Rule 8312 (FINRA BrokerCheck Disclosure), 61193-61197 [E9-27997]
Download as PDF
Federal Register / Vol. 74, No. 224 / Monday, November 23, 2009 / Notices
become the industry standard for
determining settlement value.7
ISE therefore proposes to amend its
rules to allow the closing settlement
value for the Brazilian real to be
determined based on the PTAX rate.
Doing so will reflect the current
industry standard with respect to this
product and will align trading in it with
other regulated and exchange-listed
products in the U.S. The PTAX rate is
the same as that used by the Bolsa de
Mercadorias & Futuros to cash settle its
U.S. dollar futures contract as well as
that used by the Chicago Mercantile
Exchange to cash settle its Brazilian real
futures contract.
In the event the PTAX rate is not
available, the Exchange shall calculate
the closing settlement value for options
on the Brazilian real using the WM/
Reuters Intraday Spot price
corresponding to 12:00 p.m. New York
time, which is what the Exchange
currently uses to calculate the closing
settlement values for all the FX options
that are currently listed on the
Exchange.
2. Statutory Basis
The Exchange believes the proposed
rule change is consistent with the
Securities Exchange Act of 1934 (the
‘‘Act’’) and the rules and regulations
under the Act applicable to a national
securities exchange and, in particular,
the requirements of Section 6(b) of the
Act.8 Specifically, the Exchange
believes the proposed rule change is
consistent with Section 6(b)(5) of the
Act’s 9 requirements that the rules of a
national securities exchange be
designed to promote just and equitable
principles of trade, to prevent
fraudulent and manipulative acts and,
in general, to protect investors and the
public interest. In particular, the
proposed rule change will allow the
Exchange to use the PTAX, an industryrecognized source, to determine the
closing settlement value for options on
the Brazilian real which the Exchange
expects shortly to list for trading.
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B. Self-Regulatory Organization’s
Statement on Burden on Competition
The proposed rule change does not
impose any burden on competition that
is not necessary or appropriate in
furtherance of the purposes of the Act.
7 Additional
information on the PTAX is available
on BACEN’s Web site at https://www.bcb.gov.br/
sddsi/taxacambio_i.htm.
8 15 U.S.C. 78f(b).
9 15 U.S.C. 78f(b)(5).
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The Exchange has not solicited, and
does not intend to solicit, comments on
this proposed rule change. The
Exchange has not received any
unsolicited written comments from
members or other interested parties.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Because the foregoing proposed rule
change does not significantly affect the
protection of investors or the public
interest, does not impose any significant
burden on competition, and, by its
terms, does not become operative for 30
days from the date on which it was
filed, or such shorter time as the
Commission may designate, it has
become effective pursuant to Section
19(b)(3)(A) 10 of the Act and Rule 19b–
4(f)(6) 11 thereunder. The Exchange
provided the Commission with written
notice of its intent to file the proposed
rule change, along with a brief
description and text of the proposed
rule change, at least five business days
prior to the date of filing the proposed
rule change.
At any time within 60 days of the
filing of the proposed rule change, the
Commission may summarily abrogate
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
61193
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–ISE–2009–97. This file
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room, on official business days between
the hours of 10 a.m. and 3 p.m. Copies
of the filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–ISE–
2009–97 and should be submitted on or
before December 14, 2009.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.12
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–27999 Filed 11–20–09; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Electronic Comments
[Release No. 34–61002; File No. SR–FINRA–
2009–050]
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–ISE–2009–97 on the subject
line.
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving a
Proposed Rule Change Relating to
Availability of Information Pursuant to
FINRA Rule 8312 (FINRA BrokerCheck
Disclosure)
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
10 15
11 17
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U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(6).
Frm 00091
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November 13, 2009.
I. Introduction
On July 24, 2009, the Financial
Industry Regulatory Authority, Inc.
12 17
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CFR 200.30–3(a)(12).
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Federal Register / Vol. 74, No. 224 / Monday, November 23, 2009 / Notices
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2 a
proposed rule change to make available
in BrokerCheck information about
former associated persons of a FINRA
member who were the subject of a final
regulatory action as defined in Form U4
that has been reported to the Central
Registration Depository (‘‘CRD®’’ or
‘‘CRD System’’). The proposal was
published for comment in the Federal
Register on August 7, 2009.3 The
Commission received fifty-two
comments on the proposal.4 FINRA
responded to the comments on October
15, 2009.5 This order approves the
proposed rule change.
II. Description of the Proposal
Pursuant to FINRA Rule 8312,
BrokerCheck allows the public to obtain
information regarding current and
former members, as well as associated
persons and persons who were
associated with a member within the
preceding two years. Formerly
registered persons, although no longer
in the securities industry in a registered
capacity, may, however, work in other
investment-related industries or attain
positions of trust. FINRA thus proposed
to expand the information available via
BrokerCheck to certain information with
respect to persons who were associated
with a member but who have not been
associated with a member in the
preceding two years (‘‘formerly
associated persons’’), if those persons
were the subject of any final regulatory
action, as defined in Form U4, that has
been reported to CRD via a uniform
registration form.6
‘‘Final regulatory action’’ includes
any final action of the Commission,
Commodity Futures Trading
Commission, a Federal banking agency,
the National Credit Union
Administration, another Federal
regulatory agency, a State regulatory
agency, a foreign financial regulatory
authority, or a self-regulatory
organization, including actions that
have been appealed.7 FINRA staff will
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 60462
(August 7, 2009), 74 FR 41470 (August 17, 2009
‘‘Notice’’).
4 See Exhibit A for a list of comment letters.
5 See letter to Elizabeth M. Murphy, Secretary,
Commission, from Richard E. Pullano, Associate
Vice President and Chief Counsel, FINRA, dated
October 15, 2009 (‘‘Response Letter’’).
6 See proposed FINRA Rule 8312(c).
7 See Form U4 questions 14C, 14D, and 14E, as
well as Question 7D of Form U5. See also Section
3(a)(39) of the Act.
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2 17
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review the information on Forms U4
and U5 (including predecessor
questions), as well as information filed
on Form U6, to determine whether a
formerly associated person is subject to
a final regulatory action and should be
included in BrokerCheck pursuant to
the proposed rule.8
For such formerly associated
persons,9 FINRA will disclose: (i)
Information concerning any final
regulatory action; (ii) administrative
information, such as employment and
registration history as reported on a
registration form; (iii) the most recently
submitted comment, if any, provided by
the person, if the comment is relevant
and in accordance with the procedures
established by FINRA; and (iv) dates
and names of qualification examinations
passed by the formerly associated
person, if available.10
The proposed rule change would not
expand access to other information that
is included in the CRD System, such as
customer complaints, bankruptcies,
liens, criminal events or arbitration
claims. In addition, a final regulatory
action would not include any action
limited to the revocation or suspension
of an individual’s authorization to act as
an attorney, accountant or Federal
contractor (Form U4, Question 14F).
If FINRA receives a request regarding
a formerly associated person for which
it has data in a different format, FINRA’s
staff will manually prepare the
BrokerCheck report, convert the report
to an electronic format, and make the
report available through BrokerCheck.
Once the information has been
converted to the Web CRD format it will
be available in Web CRD from that point
forward.11
8 Under the proposed rule change, FINRA may
disclose a final action that is reported by a regulator
on a Form U6 even if that action has not been
reported by an individual on a Form U4 because,
for example, the individual was not registered at the
time the final regulatory action was reported.
9 Certain information about some formerly
associated persons who have not been associated
with a member since January 1, 1999, may not be
available through BrokerCheck. As discussed more
fully in the Notice, two conditions apply to a small
percentage of individuals who were no longer
registered at the time Web CRD was established in
1999. First, not all of these individuals’ records are
available in the Web CRD format; instead, their
records exist in the Legacy CRD format. Second, for
a very small percentage of individuals, certain
administrative information is unavailable in either
the Web or Legacy CRD format.
10 See proposed FINRA Rule 8312(c).
11 FINRA stated that if it identifies or becomes
aware of potentially inappropriate information,
including customer names, confidential account
information or possibly offensive or potentially
defamatory language in a BrokerCheck report,
FINRA would balance the value of the language in
controversy for regulatory and investor protection
purposes against the objector’s asserted privacy
rights and/or potential defamation claims. Based on
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III. Summary of Comments and
FINRA’s Response
The Commission received fifty-two
comment letters on the proposed rule
change.12 Most comments focus on two
issues. First, commenters address the
provision of FINRA Rule 8312 that
provides for the release of certain
information regarding an individual
who is a current or former member or
current associated person of a member
of FINRA, or a person who has been an
associated person of a member of FINRA
within the past two preceding years.
FINRA is not making a substantive
change to this provision.13 Second,
commenters take issue with the limited
nature of the information to be disclosed
regarding formerly associated persons.
A. General Two-Year BrokerCheck
Disclosure Period
Most information available through
BrokerCheck is only available with
respect to current or former members, or
associated persons of members, or
persons who were associated persons of
FINRA members within the preceding
two years.14 Forty commenters argue
that, for investor protection purposes,
this two-year time frame should be
increased so that information remains
available to the public via BrokerCheck
for a longer period of time—anywhere
from five years to forever.15 Twelve
commenters 16 advised a six-year
disclosure period, which corresponds to
the time limit in FINRA’s rule for the
submission of arbitration claims
involving public customers (‘‘eligibility
this balancing, FINRA may determine to redact
language from BrokerCheck reports on a case-bycase basis. See the Notice, citing, e.g., Securities
Exchange Act Release No. 42402 (February 7, 2000),
65 FR 7582 (February 15, 2000) (Order Approving
SR–NASD–99–45).
12 See supra, note 4.
13 Current FINRA Rule 8312(a); proposed to be renumbered to FINRA Rule 8312(b).
14 Id. FINRA stated that some commenters
incorrectly mentioned that information regarding an
individual is ‘‘purged’’ from BrokerCheck once that
individual ceases to be registered with FINRA for
a period of two years. See, e.g., comment letters
from Lipner, Van Kampen, Sigler, Speyer, and
Claxton. FINRA stated that the information is
retained in the CRD system even though it is not
displayed through BrokerCheck and would be
available for display through BrokerCheck should
the individual reregister with FINRA or otherwise
become covered by BrokerCheck. See Response
Letter at 2.
15 See comment letters from Lipner, Van Kampen,
Sigler, Pounds, Steiner, Neuman, Bleecher, Estell,
Layne, PIABA, Schultz 1, Shewan, Port, Graham,
Speyer, AARP, Griffin, Sherman, Cornell, Evans/
Edmiston, St. John’s, Rosenfield, Ilgenfritz,
Buchwalter, Miller, Rosca, Guiliano, Greco, Sonn,
Haigney, Sutherland, Davis, Mougey, Claxton,
DeVita, Ledbetter, Gladden, McCauley, Malarney,
and Willcutts.
16 See comment letters from Pounds, Steiner,
Estell, PIABA, Schultz 1, Graham, Rosenfield,
Ilgenfritz, Miller, Greco, Sonn, and Haigney.
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rule’’).17 FINRA believes that these
comments are outside the scope of the
rule proposal, since it is not proposing
to change the two-year disclosure period
currently set forth in Rule 8312; rather,
the proposed rule change expands
BrokerCheck only with respect to
formerly associated persons who are
subject to a final regulatory action.18
Nevertheless, FINRA notes that the
two-year disclosure period coincides
with the period in which an individual
can return to the industry without being
required to requalify by examination
and the initial period in which an
individual remains subject to FINRA’s
jurisdiction.19 FINRA states that when
the two-year time frame was proposed,
FINRA believed that the two-year time
frame struck the appropriate balance
between an investor’s interest in being
easily able to obtain information about
a former registered person and a
person’s desire for privacy once he has
left the securities industry,20 and it
continues to believe that is the proper
balance today.21
Finally, FINRA disagrees with the
commenters who represent investors in
securities litigation or other matters who
suggest a six-year disclosure period,
which FINRA believes is in order to
make it easier to conduct research on
former registered persons.22 FINRA
states that the BrokerCheck system was
established principally to help members
of the public determine whether to
conduct or continue to conduct business
with a FINRA member or any of the
member’s associated persons and not for
the purpose suggested by these
commenters.23 FINRA believes that the
commenters’ attempt to link the time
limitation on the submission of claims
provided for under the eligibility rule
and the time frame for BrokerCheck
disclosure is misplaced, since the time
limitation under the eligibility rule is
determined by the date of the
occurrence or event giving rise to the
claim and has no relationship
17 See
FINRA Rule 12206.
Response Letter at 3. FINRA clarifies that
four commenters (Lipner, Neuman, AARP, and
Malarney) erroneously state that the proposal will
limit the time frame during which information on
former registered persons will be available through
BrokerCheck.
19 See Response Letter at 3, citing Securities
Exchange Act Release No. 42240 (December 16,
1999), 64 FR 72125 (December 23, 1999) (Notice of
Filing SR–NASD–99–45).
20 Id. FINRA also notes that the Commission
received no comments when FINRA proposed
establishing the two-year disclosure period for
BrokerCheck.
21 See Response Letter at 3.
22 See Response Letter at 4, citing e.g., comment
letters from PIABA, Rosca, Greco, Sonn, and
Haigney.
23 See Response Letter at 4.
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18 See
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whatsoever to the termination of an
individual’s registration with FINRA.24
Therefore, in FINRA’s opinion, the
commenters’ suggested change is
outside the scope of the rule proposal
and also would not necessarily address
the commenters’ concerns.25
B. Expanding Access to Disclosure
Information, Other Than Final
Regulatory Actions, Pertaining to
Individuals Not Registered With FINRA
for More Than Two Years
Eighteen commenters express concern
that FINRA’s proposal may be too
limiting in that it only expands
BrokerCheck with respect to those
formerly associated persons who are the
subject of a final regulatory action, and
for those persons, only with respect to
certain information.26 Many of these
commenters suggest that BrokerCheck
should include additional information,
such as arbitration claims, criminal
proceedings, and bankruptcies and
liens, contending that these other
categories are just as valuable to
investors as final regulatory actions.27
FINRA believes that these comments are
outside the scope of the rule proposal
because they pertain to categories of
disclosure that are not the subject of the
current rule proposal.28
Notwithstanding that, FINRA states
these other categories of information are
more relevant when the individual is
registered or was recently registered
(i.e., within two years) and reiterates
that it believes the proposal strikes a
balance between personal privacy and
investor protection concerns.29 FINRA
justifies one distinction by noting that
while final regulatory actions are subject
to procedures that allow an opportunity
for the person to present arguments to
a fact-finder about the allegations before
the final disposition of the matter,30
24 Id.
25 Id.
26 See comment letters from Caruso, Bleecher,
PIABA, Schultz 1, Feldman, Sherman, Lewins,
Cornell, Bakhtiari, Evans/Edmiston, St. John’s,
Rosenfield, NASAA, Guiliano, Sonn, Meyer,
Haigney, and Amato. Two commenters stated that
FINRA’s proposed rule change would apply only to
those formerly associated persons who are the
subject of a final regulatory action and who work
in other investment-related industries or positions
of trust. See comment letters from Schultz 1 and
Sonn. FINRA clarified that the proposal will, in
fact, apply to all former registered persons who are
the subject of a final regulatory action regardless of
their current occupation, if any. See Response
Letter at 4.
27 See, e.g., comment letters from PIABA, Schultz
1, Cornell, Evans/Edmiston, St. John’s, and
Rosenfield.
28 See Response Letter at 4.
29 See Response Letter at 5.
30 The formerly associated person has the
opportunity to submit a comment for publication in
BrokerCheck in response to information provided
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61195
arbitration claims may not be subject to
procedures that allow an opportunity
for the person to present arguments to
a fact-finder about the allegations before
final disposition. Further, FINRA notes,
a firm may choose to settle an
arbitration claim regardless of whether
the person wishes to contest the claim
(e.g., for business reasons). With respect
to criminal charges and convictions,
FINRA states that these claims that are
reported subsequently may have a
different disposition, which may
significantly change the meaning of the
matter as originally reported (for
example, such charges or convictions
may have been dismissed or expunged).
Finally, FINRA does not think that
reportable financial matters have the
same degree of materiality as final
regulatory actions such that they
warrant disclosure on a permanent
basis.
IV. Discussion and Commission
Findings
After carefully reviewing the
proposed rule change, the comment
letters, and the Response Letter, the
Commission finds that the proposal is
consistent with the requirements of the
Act and the rules and regulations
thereunder applicable to a national
securities association.31 In particular,
the Commission finds that the proposal
is consistent with Section 15A(b)(6) of
the Act,32 which requires, among other
things, that FINRA’s rules be designed
to prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, to remove
impediments to and perfect the
mechanism of a free and open market
and a national market system, and, in
general, to protect investors and the
public interest.
Specifically, the Commission believes
that making information available
through BrokerCheck about formerly
associated persons who were the subject
of a final regulatory action will help
members of the public to protect
themselves from unscrupulous people
and thus the proposed rule change
should help prevent fraudulent and
manipulative acts and practices, and
protect investors and the public interest.
One commenter suggests the disclosure
of this additional information may serve
through BrokerCheck if the comment is in the form
and in accordance with the procedures established
by FINRA and relates to the information provided
through BrokerCheck.
31 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
32 15 U.S.C. 78o–3(b)(6).
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as a deterrent to fraudulent activity.33
The Commission believes that the
information FINRA proposes to disclose
is relevant to investors and members of
the public who wish to educate
themselves with respect to the
professional history of a formerly
associated person. It is possible that a
formerly associated person could
become a financial planner or work in
another related field where his
securities record would help members
of the public decide if they should
accept his financial advice or rely on his
advice or expertise. One commenter
suggested a formerly associated person
could serve as a non-public arbitrator.34
Clearly, in any of these circumstances,
the formerly associated person’s
BrokerCheck information would be
relevant in determining whether to do
business with him, or, in the case of a
claimant, in deciding whether to
challenge a potential arbitrator.
The Commission agrees that the
concerns raised by commenters who
believe that the time frame for general
disclosure should be increased are
outside the scope of this proposal.
However, the categories of information
that should be disclosed for formerly
associated persons is within the scope
of the instant proposal and the
commenters make a number of
legitimate arguments with respect to the
usefulness of the additional information
they seek to have disclosed. The
Commission understands that certain
commenters, as well as other members
of the public, may utilize information in
BrokerCheck in considering whether to
bring action against a formerly
associated person for potentially
actionable deeds 35 and believes that
this is a legitimate use for BrokerCheck.
The Commission recognizes that the
public’s ability to access information,
whether to inquire about a registered
person or to obtain information in
connection with an alleged wrongdoing
of a formerly associated person may
serve to protect investors, the integrity
of the marketplace, and the public
interest. The Commission urges the
public to utilize all sources of
information, particularly the databases
of the State regulators, as well as legal
search engines and records searches, in
conducting a thorough search of any
associated person’s activities.
The Commission notes that FINRA
stated it would continue to evaluate all
aspects of the BrokerCheck program to
determine whether future circumstances
should lead to greater disclosure
33 See
Cornell letter.
Estell letter.
35 See supra, note 22.
34 See
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16:37 Nov 20, 2009
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through BrokerCheck.36 FINRA has a
statutory obligation to make information
available to the public and,37 as stated
in the past, the Commission believes
that FINRA should continuously strive
to improve BrokerCheck because it is a
valuable tool for the public in deciding
whether to work with an industry
member.38 The changes proposed in this
filing will enhance BrokerCheck by
including more information that should
prove useful to the general public.
For the reasons discussed above, the
Commission finds that the rule change
is consistent with the Act.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,39 that the
proposed rule change (SR–FINRA–
2009–050), be, and hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.40
Florence E. Harmon,
Deputy Secretary.
Exhibit A—List of Comment Letters
Received for FINRA–2009–050
1. Daniel W. Roberts, President/CEO,
Roberts & Ryan Investments Inc., dated
August 21, 2009 (‘‘Roberts’’).
2. Seth E. Lipner, Professor of Law,
Zicklin School of Business, Baruch
College, CUNY, dated August 27, 2009
(‘‘Lipner’’).
3. Al Van Kampen, Attorney at Law,
dated August 31, 2009 (‘‘Van Kampen’’).
4. James A. Sigler, Esq., dated August
31, 2009 (‘‘Sigler’’).
5. Herb Pounds, dated August 31,
2009 (‘‘Pounds’’).
6. Leonard Steiner, Lawyer, dated
August 31, 2009 (‘‘Steiner’’).
7. David P. Neuman, Stoltmann Law
Offices, PC, dated August 31, 2009
(‘‘Neuman’’).
8. Steven B. Caruso, Esq., Maddox
Hargett & Caruso, P.C., dated September
1, 2009 (‘‘Caruso’’).
9. Rob Bleecher, Attorney, dated
September 1, 2009 (‘‘Bleecher’’).
10. Barry D. Estell, Esq., dated
September 1, 2009 (‘‘Estell’’).
11. Richard M. Layne, Esq., Law
Office of Richard M. Layne, dated
September 1, 2009 (‘‘Layne’’).
12. Brian N. Smiley, President, Public
Investors Arbitration Bar Association,
dated September 4, 2009 (‘‘PIABA’’).
13. Laurence S. Schultz, Driggers,
Schultz & Herbst, P.C., dated September
4, 2009 (‘‘Schultz 1’’).
36 See
Response Letter at 5.
Section 15A(i) of the Act.
38 See, e.g., Securities Exchange Act Release No.
59916 (May 13, 2009), 74 FR 23750 (May 20, 2009).
39 15 U.S.C. 78s(b)(2).
40 17 CFR 200.30–3(a)(12).
37 See
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14. Scott R. Shewan, Pape Shewan
LLP, dated September 4, 2009
(‘‘Shewan’’).
15. Robert C. Port, Esq., dated
September 4, 2009 (‘‘Port’’).
16. Jan Graham, Graham Law Offices,
dated September 4, 2009 (‘‘Graham’’).
17. Jeffrey A. Feldman, dated
September 7, 2009 (‘‘Feldman’’).
18. Debra G. Speyer, Esq., Law Offices
of Debra G. Speyer, dated September 7,
2009 (‘‘Speyer’’).
19. Tim Canning, Law Offices of
Timothy A. Canning, dated September
8, 2009 (‘‘Canning’’).
20. David Certner, Legislative Counsel
and Legislative Policy Director, AARP,
dated September 8, 2009 (‘‘AARP’’).
21. Keith L. Griffin, Griffin Law Firm,
LLC, dated September 8, 2009
(‘‘Griffin’’).
22. Steven M. Sherman, Sherman
Business Law, received September 8,
2009 (‘‘Sherman’’).
23. Richard A. Lewins, Esq., dated
September 8, 2009 (‘‘Lewins’’).
24. William A. Jacobson, Esq.,
Associate Clinical Professor of Law,
Director, Cornell Securities Law Clinic,
dated September 8, 2009 (‘‘Cornell’’).
25. Ryan K. Bakhtiari, Aidikoff, Uhl
and Bakhtiari, dated September 8, 2009
(‘‘Bakhtiari’’).
26. Jonathan W. Evans and Michael S.
Edmiston, dated September 8, 2009
(‘‘Evans/Edmiston’’).
27. Christine Lazaro, Supervising
Attorney, Lisa A. Catalano, Director,
Peter J. Harrington, Legal Intern,
Securities Arbitration Clinic, St. John’s
University School of Law, dated
September 8, 2009 (‘‘St. John’s’’).
28. William S. Shepherd, Managing
Partner, Shepherd Smith Edwards
Kantas, LLP, dated September 8, 2009
(‘‘Shepherd’’).
29. Howard Rosenfield, Law Offices of
Howard Rosenfield, received September
8, 2009 (‘‘Rosenfield’’).
30. Rex Staples, General Counsel,
North American Securities
Administrators Association, dated
September 8, 2009 (‘‘NASAA’’).
31. Scott C. Ilgenfritz, Johnson, Pope,
Bokor, Ruppel & Burns, LLP, dated
September 8, 2009 (‘‘Ilgenfritz’’).
32. Steve A. Buchwalter, Esq., dated
September 8, 2009 (‘‘Buchwalter’’).
33. John Miller, Attorney, Swanson
Midgley, LLC, dated September 9, 2009
(‘‘Miller’’).
34. Alin L. Rosca, Attorney at Law,
John S. Chapman & Associates, LLC,
received September 9, 2009 (‘‘Rosca’’).
35. Nicholas J. Guiliano, The Guiliano
Law Firm, received September 9, 2009
(‘‘Guiliano’’).
36. W. Scott Greco, Greco Greco, P.C.,
dated September 9, 2009 (‘‘Greco’’).
E:\FR\FM\23NON1.SGM
23NON1
Federal Register / Vol. 74, No. 224 / Monday, November 23, 2009 / Notices
37. Jeffrey Sonn, Esq., Sonn & Erez,
PLC, dated September 9, 2009 (‘‘Sonn’’).
38. Stephen P. Meyer, Esq., Meyer,
Ford & Glasser, dated September 10,
2009 (‘‘Meyer’’).
39. Dayton P. Haigney, III, Attorney at
Law, dated September 10, 2009
(‘‘Haigney’’).
40. John E. Sutherland, Brickley,
Sears & Sorett, P.A., dated September
11, 2009 (‘‘Sutherland’’).
41. Theodore M. Davis, Esq., dated
September 11, 2009 (‘‘Davis’’).
42. Peter J. Mougey, Esq., dated
September 14, 2009 (‘‘Mougey’’).
43. Roger F. Claxton, Law Office of
Roger F. Claxton, dated September 15,
2009 (‘‘Claxton’’).
44. Richard D. DeVita, Esq., dated
September 15, 2009 (‘‘DeVita’’).
45. Dale Ledbetter, Ledbetter &
Associates, P.A., dated September 16,
2009 (‘‘Ledbetter’’).
46. William J. Gladden, JD, CFP, dated
September 16, 2009 (‘‘Gladden’’).
47. Steven M. McCauley, Esq., dated
September 16, 2009 (‘‘McCauley’’).
48. Michael W. Malarney, Esq., The
Pearl Law Firm, P.A., dated September
17, 2009 (‘‘Malarney’’).
49. Ronald M. Amato, Esq., Shaheen,
Novoselsky, Staat, Filipowski Eccleston,
PC, dated September 18, 2009
(‘‘Amato’’).
50. Thomas P. Willcutts, Willcutts
Law Group, LLC, dated September 21,
2009 (‘‘Willcutts’’).
51. Scot D. Bernstein, Law Offices of
Scot D. Bernstein, dated September 24,
2009 (‘‘Bernstein’’).
52. Laurence S. Schultz, Driggers,
Schultz & Herbst, P.C., dated September
30, 2009 (‘‘Schultz 2’’).
[FR Doc. E9–27997 Filed 11–20–09; 8:45 am]
BILLING CODE 8011–01–P
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared by NASDAQ. The Commission
is publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
NASDAQ proposes to modify pricing
for NASDAQ members using the Nasdaq
Market Center. This proposed rule
change, which is effective upon filing,
will become operative on November 2,
2009. The text of the proposed rule
change is available at https://
nasdaqomx.cchwallstreet.com/, at
NASDAQ’s principal office, and at the
Commission’s Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of these statements may be examined at
the places specified in Item IV below.
The self-regulatory organization has
prepared summaries, set forth in
Sections A, B, and C below, of the most
significant aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–60980; File No. SR–
NASDAQ–2009–098]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Modify Fees
for Members Using the NASDAQ
Options Market
jlentini on DSKJ8SOYB1PROD with NOTICES
November 10, 2009.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on October
30, 2009, The NASDAQ Stock Market
LLC (‘‘NASDAQ’’) filed with the
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
VerDate Nov<24>2008
16:37 Nov 20, 2009
Jkt 220001
Nasdaq is modifying NASDAQ Rule
7050, the fee schedule for NOM,
regarding orders with an account type of
‘‘Customer.’’ Specifically, Nasdaq is
establishing a fee of $0.35 per executed
contract for Customer orders in Penny
Pilot options, as opposed to the fee of
$0.20 that has applied to such orders
since July 2009. Nasdaq notes that this
fee remains lower than the fees that
other options exchanges apply to such
customer orders.
Nasdaq believes that the proposed
fees are competitive, fair and
reasonable, and non-discriminatory in
that they apply equally to all similarly
situated members and customers. As
with all fees, Nasdaq may adjust these
proposed fees in response to
competitive conditions by filing a new
proposed rule change.
PO 00000
Frm 00095
Fmt 4703
Sfmt 4703
61197
2. Statutory Basis
Nasdaq believes that the proposed
rule change is consistent with the
provisions of Section 6 of the Act,3 in
general, and with Section 6(b)(4) of the
Act,4 in particular, in that it provides for
the equitable allocation of reasonable
dues, fees and other charges among
members and issuers and other persons
using any facility or system which
NASDAQ operates or controls.
Consistent with past practice, the
proposed change identifies a class of
person subject to transaction execution
fees based on the role of that class in
bringing order flow to NASDAQ.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
NASDAQ does not believe that the
proposed rule change will result in any
burden on competition that is not
necessary or appropriate in furtherance
of the purposes of the Act, as amended.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments were neither
solicited nor received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act 5 and
subparagraph (f)(2) of Rule 19b–4
thereunder.6 At any time within 60 days
of the filing of the proposed rule change,
the Commission may summarily
abrogate such rule change if it appears
to the Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
3 15
U.S.C. 78f.
U.S.C. 78f(b)(4).
5 15 U.S.C. 78s(b)(3)(a)(ii).
6 17 CFR 240.19b–4(f)(2).
4 15
E:\FR\FM\23NON1.SGM
23NON1
Agencies
[Federal Register Volume 74, Number 224 (Monday, November 23, 2009)]
[Notices]
[Pages 61193-61197]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-27997]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-61002; File No. SR-FINRA-2009-050]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving a Proposed Rule Change Relating to
Availability of Information Pursuant to FINRA Rule 8312 (FINRA
BrokerCheck Disclosure)
November 13, 2009.
I. Introduction
On July 24, 2009, the Financial Industry Regulatory Authority, Inc.
[[Page 61194]]
(``FINRA'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act''),\1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change to make available in BrokerCheck information about
former associated persons of a FINRA member who were the subject of a
final regulatory action as defined in Form U4 that has been reported to
the Central Registration Depository (``CRD[supreg]'' or ``CRD
System''). The proposal was published for comment in the Federal
Register on August 7, 2009.\3\ The Commission received fifty-two
comments on the proposal.\4\ FINRA responded to the comments on October
15, 2009.\5\ This order approves the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 60462 (August 7,
2009), 74 FR 41470 (August 17, 2009 ``Notice'').
\4\ See Exhibit A for a list of comment letters.
\5\ See letter to Elizabeth M. Murphy, Secretary, Commission,
from Richard E. Pullano, Associate Vice President and Chief Counsel,
FINRA, dated October 15, 2009 (``Response Letter'').
---------------------------------------------------------------------------
II. Description of the Proposal
Pursuant to FINRA Rule 8312, BrokerCheck allows the public to
obtain information regarding current and former members, as well as
associated persons and persons who were associated with a member within
the preceding two years. Formerly registered persons, although no
longer in the securities industry in a registered capacity, may,
however, work in other investment-related industries or attain
positions of trust. FINRA thus proposed to expand the information
available via BrokerCheck to certain information with respect to
persons who were associated with a member but who have not been
associated with a member in the preceding two years (``formerly
associated persons''), if those persons were the subject of any final
regulatory action, as defined in Form U4, that has been reported to CRD
via a uniform registration form.\6\
---------------------------------------------------------------------------
\6\ See proposed FINRA Rule 8312(c).
---------------------------------------------------------------------------
``Final regulatory action'' includes any final action of the
Commission, Commodity Futures Trading Commission, a Federal banking
agency, the National Credit Union Administration, another Federal
regulatory agency, a State regulatory agency, a foreign financial
regulatory authority, or a self-regulatory organization, including
actions that have been appealed.\7\ FINRA staff will review the
information on Forms U4 and U5 (including predecessor questions), as
well as information filed on Form U6, to determine whether a formerly
associated person is subject to a final regulatory action and should be
included in BrokerCheck pursuant to the proposed rule.\8\
---------------------------------------------------------------------------
\7\ See Form U4 questions 14C, 14D, and 14E, as well as Question
7D of Form U5. See also Section 3(a)(39) of the Act.
\8\ Under the proposed rule change, FINRA may disclose a final
action that is reported by a regulator on a Form U6 even if that
action has not been reported by an individual on a Form U4 because,
for example, the individual was not registered at the time the final
regulatory action was reported.
---------------------------------------------------------------------------
For such formerly associated persons,\9\ FINRA will disclose: (i)
Information concerning any final regulatory action; (ii) administrative
information, such as employment and registration history as reported on
a registration form; (iii) the most recently submitted comment, if any,
provided by the person, if the comment is relevant and in accordance
with the procedures established by FINRA; and (iv) dates and names of
qualification examinations passed by the formerly associated person, if
available.\10\
---------------------------------------------------------------------------
\9\ Certain information about some formerly associated persons
who have not been associated with a member since January 1, 1999,
may not be available through BrokerCheck. As discussed more fully in
the Notice, two conditions apply to a small percentage of
individuals who were no longer registered at the time Web CRD was
established in 1999. First, not all of these individuals' records
are available in the Web CRD format; instead, their records exist in
the Legacy CRD format. Second, for a very small percentage of
individuals, certain administrative information is unavailable in
either the Web or Legacy CRD format.
\10\ See proposed FINRA Rule 8312(c).
---------------------------------------------------------------------------
The proposed rule change would not expand access to other
information that is included in the CRD System, such as customer
complaints, bankruptcies, liens, criminal events or arbitration claims.
In addition, a final regulatory action would not include any action
limited to the revocation or suspension of an individual's
authorization to act as an attorney, accountant or Federal contractor
(Form U4, Question 14F).
If FINRA receives a request regarding a formerly associated person
for which it has data in a different format, FINRA's staff will
manually prepare the BrokerCheck report, convert the report to an
electronic format, and make the report available through BrokerCheck.
Once the information has been converted to the Web CRD format it will
be available in Web CRD from that point forward.\11\
---------------------------------------------------------------------------
\11\ FINRA stated that if it identifies or becomes aware of
potentially inappropriate information, including customer names,
confidential account information or possibly offensive or
potentially defamatory language in a BrokerCheck report, FINRA would
balance the value of the language in controversy for regulatory and
investor protection purposes against the objector's asserted privacy
rights and/or potential defamation claims. Based on this balancing,
FINRA may determine to redact language from BrokerCheck reports on a
case-by-case basis. See the Notice, citing, e.g., Securities
Exchange Act Release No. 42402 (February 7, 2000), 65 FR 7582
(February 15, 2000) (Order Approving SR-NASD-99-45).
---------------------------------------------------------------------------
III. Summary of Comments and FINRA's Response
The Commission received fifty-two comment letters on the proposed
rule change.\12\ Most comments focus on two issues. First, commenters
address the provision of FINRA Rule 8312 that provides for the release
of certain information regarding an individual who is a current or
former member or current associated person of a member of FINRA, or a
person who has been an associated person of a member of FINRA within
the past two preceding years. FINRA is not making a substantive change
to this provision.\13\ Second, commenters take issue with the limited
nature of the information to be disclosed regarding formerly associated
persons.
---------------------------------------------------------------------------
\12\ See supra, note 4.
\13\ Current FINRA Rule 8312(a); proposed to be re-numbered to
FINRA Rule 8312(b).
---------------------------------------------------------------------------
A. General Two-Year BrokerCheck Disclosure Period
Most information available through BrokerCheck is only available
with respect to current or former members, or associated persons of
members, or persons who were associated persons of FINRA members within
the preceding two years.\14\ Forty commenters argue that, for investor
protection purposes, this two-year time frame should be increased so
that information remains available to the public via BrokerCheck for a
longer period of time--anywhere from five years to forever.\15\ Twelve
commenters \16\ advised a six-year disclosure period, which corresponds
to the time limit in FINRA's rule for the submission of arbitration
claims involving public customers (``eligibility
[[Page 61195]]
rule'').\17\ FINRA believes that these comments are outside the scope
of the rule proposal, since it is not proposing to change the two-year
disclosure period currently set forth in Rule 8312; rather, the
proposed rule change expands BrokerCheck only with respect to formerly
associated persons who are subject to a final regulatory action.\18\
---------------------------------------------------------------------------
\14\ Id. FINRA stated that some commenters incorrectly mentioned
that information regarding an individual is ``purged'' from
BrokerCheck once that individual ceases to be registered with FINRA
for a period of two years. See, e.g., comment letters from Lipner,
Van Kampen, Sigler, Speyer, and Claxton. FINRA stated that the
information is retained in the CRD system even though it is not
displayed through BrokerCheck and would be available for display
through BrokerCheck should the individual reregister with FINRA or
otherwise become covered by BrokerCheck. See Response Letter at 2.
\15\ See comment letters from Lipner, Van Kampen, Sigler,
Pounds, Steiner, Neuman, Bleecher, Estell, Layne, PIABA, Schultz 1,
Shewan, Port, Graham, Speyer, AARP, Griffin, Sherman, Cornell,
Evans/Edmiston, St. John's, Rosenfield, Ilgenfritz, Buchwalter,
Miller, Rosca, Guiliano, Greco, Sonn, Haigney, Sutherland, Davis,
Mougey, Claxton, DeVita, Ledbetter, Gladden, McCauley, Malarney, and
Willcutts.
\16\ See comment letters from Pounds, Steiner, Estell, PIABA,
Schultz 1, Graham, Rosenfield, Ilgenfritz, Miller, Greco, Sonn, and
Haigney.
\17\ See FINRA Rule 12206.
\18\ See Response Letter at 3. FINRA clarifies that four
commenters (Lipner, Neuman, AARP, and Malarney) erroneously state
that the proposal will limit the time frame during which information
on former registered persons will be available through BrokerCheck.
---------------------------------------------------------------------------
Nevertheless, FINRA notes that the two-year disclosure period
coincides with the period in which an individual can return to the
industry without being required to requalify by examination and the
initial period in which an individual remains subject to FINRA's
jurisdiction.\19\ FINRA states that when the two-year time frame was
proposed, FINRA believed that the two-year time frame struck the
appropriate balance between an investor's interest in being easily able
to obtain information about a former registered person and a person's
desire for privacy once he has left the securities industry,\20\ and it
continues to believe that is the proper balance today.\21\
---------------------------------------------------------------------------
\19\ See Response Letter at 3, citing Securities Exchange Act
Release No. 42240 (December 16, 1999), 64 FR 72125 (December 23,
1999) (Notice of Filing SR-NASD-99-45).
\20\ Id. FINRA also notes that the Commission received no
comments when FINRA proposed establishing the two-year disclosure
period for BrokerCheck.
\21\ See Response Letter at 3.
---------------------------------------------------------------------------
Finally, FINRA disagrees with the commenters who represent
investors in securities litigation or other matters who suggest a six-
year disclosure period, which FINRA believes is in order to make it
easier to conduct research on former registered persons.\22\ FINRA
states that the BrokerCheck system was established principally to help
members of the public determine whether to conduct or continue to
conduct business with a FINRA member or any of the member's associated
persons and not for the purpose suggested by these commenters.\23\
FINRA believes that the commenters' attempt to link the time limitation
on the submission of claims provided for under the eligibility rule and
the time frame for BrokerCheck disclosure is misplaced, since the time
limitation under the eligibility rule is determined by the date of the
occurrence or event giving rise to the claim and has no relationship
whatsoever to the termination of an individual's registration with
FINRA.\24\ Therefore, in FINRA's opinion, the commenters' suggested
change is outside the scope of the rule proposal and also would not
necessarily address the commenters' concerns.\25\
---------------------------------------------------------------------------
\22\ See Response Letter at 4, citing e.g., comment letters from
PIABA, Rosca, Greco, Sonn, and Haigney.
\23\ See Response Letter at 4.
\24\ Id.
\25\ Id.
---------------------------------------------------------------------------
B. Expanding Access to Disclosure Information, Other Than Final
Regulatory Actions, Pertaining to Individuals Not Registered With FINRA
for More Than Two Years
Eighteen commenters express concern that FINRA's proposal may be
too limiting in that it only expands BrokerCheck with respect to those
formerly associated persons who are the subject of a final regulatory
action, and for those persons, only with respect to certain
information.\26\ Many of these commenters suggest that BrokerCheck
should include additional information, such as arbitration claims,
criminal proceedings, and bankruptcies and liens, contending that these
other categories are just as valuable to investors as final regulatory
actions.\27\ FINRA believes that these comments are outside the scope
of the rule proposal because they pertain to categories of disclosure
that are not the subject of the current rule proposal.\28\
---------------------------------------------------------------------------
\26\ See comment letters from Caruso, Bleecher, PIABA, Schultz
1, Feldman, Sherman, Lewins, Cornell, Bakhtiari, Evans/Edmiston, St.
John's, Rosenfield, NASAA, Guiliano, Sonn, Meyer, Haigney, and
Amato. Two commenters stated that FINRA's proposed rule change would
apply only to those formerly associated persons who are the subject
of a final regulatory action and who work in other investment-
related industries or positions of trust. See comment letters from
Schultz 1 and Sonn. FINRA clarified that the proposal will, in fact,
apply to all former registered persons who are the subject of a
final regulatory action regardless of their current occupation, if
any. See Response Letter at 4.
\27\ See, e.g., comment letters from PIABA, Schultz 1, Cornell,
Evans/Edmiston, St. John's, and Rosenfield.
\28\ See Response Letter at 4.
---------------------------------------------------------------------------
Notwithstanding that, FINRA states these other categories of
information are more relevant when the individual is registered or was
recently registered (i.e., within two years) and reiterates that it
believes the proposal strikes a balance between personal privacy and
investor protection concerns.\29\ FINRA justifies one distinction by
noting that while final regulatory actions are subject to procedures
that allow an opportunity for the person to present arguments to a
fact-finder about the allegations before the final disposition of the
matter,\30\ arbitration claims may not be subject to procedures that
allow an opportunity for the person to present arguments to a fact-
finder about the allegations before final disposition. Further, FINRA
notes, a firm may choose to settle an arbitration claim regardless of
whether the person wishes to contest the claim (e.g., for business
reasons). With respect to criminal charges and convictions, FINRA
states that these claims that are reported subsequently may have a
different disposition, which may significantly change the meaning of
the matter as originally reported (for example, such charges or
convictions may have been dismissed or expunged). Finally, FINRA does
not think that reportable financial matters have the same degree of
materiality as final regulatory actions such that they warrant
disclosure on a permanent basis.
---------------------------------------------------------------------------
\29\ See Response Letter at 5.
\30\ The formerly associated person has the opportunity to
submit a comment for publication in BrokerCheck in response to
information provided through BrokerCheck if the comment is in the
form and in accordance with the procedures established by FINRA and
relates to the information provided through BrokerCheck.
---------------------------------------------------------------------------
IV. Discussion and Commission Findings
After carefully reviewing the proposed rule change, the comment
letters, and the Response Letter, the Commission finds that the
proposal is consistent with the requirements of the Act and the rules
and regulations thereunder applicable to a national securities
association.\31\ In particular, the Commission finds that the proposal
is consistent with Section 15A(b)(6) of the Act,\32\ which requires,
among other things, that FINRA's rules be designed to prevent
fraudulent and manipulative acts and practices, to promote just and
equitable principles of trade, to remove impediments to and perfect the
mechanism of a free and open market and a national market system, and,
in general, to protect investors and the public interest.
---------------------------------------------------------------------------
\31\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
\32\ 15 U.S.C. 78o-3(b)(6).
---------------------------------------------------------------------------
Specifically, the Commission believes that making information
available through BrokerCheck about formerly associated persons who
were the subject of a final regulatory action will help members of the
public to protect themselves from unscrupulous people and thus the
proposed rule change should help prevent fraudulent and manipulative
acts and practices, and protect investors and the public interest. One
commenter suggests the disclosure of this additional information may
serve
[[Page 61196]]
as a deterrent to fraudulent activity.\33\ The Commission believes that
the information FINRA proposes to disclose is relevant to investors and
members of the public who wish to educate themselves with respect to
the professional history of a formerly associated person. It is
possible that a formerly associated person could become a financial
planner or work in another related field where his securities record
would help members of the public decide if they should accept his
financial advice or rely on his advice or expertise. One commenter
suggested a formerly associated person could serve as a non-public
arbitrator.\34\ Clearly, in any of these circumstances, the formerly
associated person's BrokerCheck information would be relevant in
determining whether to do business with him, or, in the case of a
claimant, in deciding whether to challenge a potential arbitrator.
---------------------------------------------------------------------------
\33\ See Cornell letter.
\34\ See Estell letter.
---------------------------------------------------------------------------
The Commission agrees that the concerns raised by commenters who
believe that the time frame for general disclosure should be increased
are outside the scope of this proposal. However, the categories of
information that should be disclosed for formerly associated persons is
within the scope of the instant proposal and the commenters make a
number of legitimate arguments with respect to the usefulness of the
additional information they seek to have disclosed. The Commission
understands that certain commenters, as well as other members of the
public, may utilize information in BrokerCheck in considering whether
to bring action against a formerly associated person for potentially
actionable deeds \35\ and believes that this is a legitimate use for
BrokerCheck. The Commission recognizes that the public's ability to
access information, whether to inquire about a registered person or to
obtain information in connection with an alleged wrongdoing of a
formerly associated person may serve to protect investors, the
integrity of the marketplace, and the public interest. The Commission
urges the public to utilize all sources of information, particularly
the databases of the State regulators, as well as legal search engines
and records searches, in conducting a thorough search of any associated
person's activities.
---------------------------------------------------------------------------
\35\ See supra, note 22.
---------------------------------------------------------------------------
The Commission notes that FINRA stated it would continue to
evaluate all aspects of the BrokerCheck program to determine whether
future circumstances should lead to greater disclosure through
BrokerCheck.\36\ FINRA has a statutory obligation to make information
available to the public and,\37\ as stated in the past, the Commission
believes that FINRA should continuously strive to improve BrokerCheck
because it is a valuable tool for the public in deciding whether to
work with an industry member.\38\ The changes proposed in this filing
will enhance BrokerCheck by including more information that should
prove useful to the general public.
---------------------------------------------------------------------------
\36\ See Response Letter at 5.
\37\ See Section 15A(i) of the Act.
\38\ See, e.g., Securities Exchange Act Release No. 59916 (May
13, 2009), 74 FR 23750 (May 20, 2009).
---------------------------------------------------------------------------
For the reasons discussed above, the Commission finds that the rule
change is consistent with the Act.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\39\ that the proposed rule change (SR-FINRA-2009-050), be, and
hereby is, approved.
---------------------------------------------------------------------------
\39\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\40\
---------------------------------------------------------------------------
\40\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------
Florence E. Harmon,
Deputy Secretary.
Exhibit A--List of Comment Letters Received for FINRA-2009-050
1. Daniel W. Roberts, President/CEO, Roberts & Ryan Investments
Inc., dated August 21, 2009 (``Roberts'').
2. Seth E. Lipner, Professor of Law, Zicklin School of Business,
Baruch College, CUNY, dated August 27, 2009 (``Lipner'').
3. Al Van Kampen, Attorney at Law, dated August 31, 2009 (``Van
Kampen'').
4. James A. Sigler, Esq., dated August 31, 2009 (``Sigler'').
5. Herb Pounds, dated August 31, 2009 (``Pounds'').
6. Leonard Steiner, Lawyer, dated August 31, 2009 (``Steiner'').
7. David P. Neuman, Stoltmann Law Offices, PC, dated August 31,
2009 (``Neuman'').
8. Steven B. Caruso, Esq., Maddox Hargett & Caruso, P.C., dated
September 1, 2009 (``Caruso'').
9. Rob Bleecher, Attorney, dated September 1, 2009 (``Bleecher'').
10. Barry D. Estell, Esq., dated September 1, 2009 (``Estell'').
11. Richard M. Layne, Esq., Law Office of Richard M. Layne, dated
September 1, 2009 (``Layne'').
12. Brian N. Smiley, President, Public Investors Arbitration Bar
Association, dated September 4, 2009 (``PIABA'').
13. Laurence S. Schultz, Driggers, Schultz & Herbst, P.C., dated
September 4, 2009 (``Schultz 1'').
14. Scott R. Shewan, Pape Shewan LLP, dated September 4, 2009
(``Shewan'').
15. Robert C. Port, Esq., dated September 4, 2009 (``Port'').
16. Jan Graham, Graham Law Offices, dated September 4, 2009
(``Graham'').
17. Jeffrey A. Feldman, dated September 7, 2009 (``Feldman'').
18. Debra G. Speyer, Esq., Law Offices of Debra G. Speyer, dated
September 7, 2009 (``Speyer'').
19. Tim Canning, Law Offices of Timothy A. Canning, dated September
8, 2009 (``Canning'').
20. David Certner, Legislative Counsel and Legislative Policy
Director, AARP, dated September 8, 2009 (``AARP'').
21. Keith L. Griffin, Griffin Law Firm, LLC, dated September 8,
2009 (``Griffin'').
22. Steven M. Sherman, Sherman Business Law, received September 8,
2009 (``Sherman'').
23. Richard A. Lewins, Esq., dated September 8, 2009 (``Lewins'').
24. William A. Jacobson, Esq., Associate Clinical Professor of Law,
Director, Cornell Securities Law Clinic, dated September 8, 2009
(``Cornell'').
25. Ryan K. Bakhtiari, Aidikoff, Uhl and Bakhtiari, dated September
8, 2009 (``Bakhtiari'').
26. Jonathan W. Evans and Michael S. Edmiston, dated September 8,
2009 (``Evans/Edmiston'').
27. Christine Lazaro, Supervising Attorney, Lisa A. Catalano,
Director, Peter J. Harrington, Legal Intern, Securities Arbitration
Clinic, St. John's University School of Law, dated September 8, 2009
(``St. John's'').
28. William S. Shepherd, Managing Partner, Shepherd Smith Edwards
Kantas, LLP, dated September 8, 2009 (``Shepherd'').
29. Howard Rosenfield, Law Offices of Howard Rosenfield, received
September 8, 2009 (``Rosenfield'').
30. Rex Staples, General Counsel, North American Securities
Administrators Association, dated September 8, 2009 (``NASAA'').
31. Scott C. Ilgenfritz, Johnson, Pope, Bokor, Ruppel & Burns, LLP,
dated September 8, 2009 (``Ilgenfritz'').
32. Steve A. Buchwalter, Esq., dated September 8, 2009
(``Buchwalter'').
33. John Miller, Attorney, Swanson Midgley, LLC, dated September 9,
2009 (``Miller'').
34. Alin L. Rosca, Attorney at Law, John S. Chapman & Associates,
LLC, received September 9, 2009 (``Rosca'').
35. Nicholas J. Guiliano, The Guiliano Law Firm, received September
9, 2009 (``Guiliano'').
36. W. Scott Greco, Greco Greco, P.C., dated September 9, 2009
(``Greco'').
[[Page 61197]]
37. Jeffrey Sonn, Esq., Sonn & Erez, PLC, dated September 9, 2009
(``Sonn'').
38. Stephen P. Meyer, Esq., Meyer, Ford & Glasser, dated September
10, 2009 (``Meyer'').
39. Dayton P. Haigney, III, Attorney at Law, dated September 10,
2009 (``Haigney'').
40. John E. Sutherland, Brickley, Sears & Sorett, P.A., dated
September 11, 2009 (``Sutherland'').
41. Theodore M. Davis, Esq., dated September 11, 2009 (``Davis'').
42. Peter J. Mougey, Esq., dated September 14, 2009 (``Mougey'').
43. Roger F. Claxton, Law Office of Roger F. Claxton, dated
September 15, 2009 (``Claxton'').
44. Richard D. DeVita, Esq., dated September 15, 2009 (``DeVita'').
45. Dale Ledbetter, Ledbetter & Associates, P.A., dated September
16, 2009 (``Ledbetter'').
46. William J. Gladden, JD, CFP, dated September 16, 2009
(``Gladden'').
47. Steven M. McCauley, Esq., dated September 16, 2009
(``McCauley'').
48. Michael W. Malarney, Esq., The Pearl Law Firm, P.A., dated
September 17, 2009 (``Malarney'').
49. Ronald M. Amato, Esq., Shaheen, Novoselsky, Staat, Filipowski
Eccleston, PC, dated September 18, 2009 (``Amato'').
50. Thomas P. Willcutts, Willcutts Law Group, LLC, dated September
21, 2009 (``Willcutts'').
51. Scot D. Bernstein, Law Offices of Scot D. Bernstein, dated
September 24, 2009 (``Bernstein'').
52. Laurence S. Schultz, Driggers, Schultz & Herbst, P.C., dated
September 30, 2009 (``Schultz 2'').
[FR Doc. E9-27997 Filed 11-20-09; 8:45 am]
BILLING CODE 8011-01-P