Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of Amendment No. 1 and Order Granting Accelerated Approval of a Proposed Rule Change, as Modified by Amendment No. 1, Relating to Outside Business Activities of Registered Persons, 53362-53366 [2010-21606]
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53362
Federal Register / Vol. 75, No. 168 / Tuesday, August 31, 2010 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–62762; File No. SR–FINRA–
2009–042]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Amendment No. 1 and Order Granting
Accelerated Approval of a Proposed
Rule Change, as Modified by
Amendment No. 1, Relating to Outside
Business Activities of Registered
Persons
August 23, 2010.
srobinson on DSKHWCL6B1PROD with NOTICES
On June 8, 2009, Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’)
(f/k/a National Association of Securities
Dealers, Inc. (‘‘NASD’’)) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) a proposed
rule change relating to the outside
business activities of registered persons.
FINRA proposed to adopt NASD Rule
3030 (Outside Business Activities of an
Associated Person) as FINRA Rule 3270
(Outside Business Activities of
Registered Persons) in the consolidated
FINRA rulebook with moderate changes.
The proposed rule change would delete
Incorporated NYSE Rule 346
(Limitations—Employment and
Association with Members and Member
Organizations) and its interpretations.
The proposed rule change was
published for comment in the Federal
Register on July 8, 2009.1 The
Commission received six comments on
the proposed rule change.2 On July 30,
2010, FINRA responded to the
comments.3 Also on July 30, 2010,
FINRA filed Amendment No. 1 to the
proposed rule change.
1 See Securities Exchange Act Release No. 60199
(June 30, 2009), 74 FR 32668 (July 8, 2009).
2 See letter from Dale E. Brown, CAE, Financial
Services Institute, to Elizabeth M. Murphy,
Secretary, Commission, dated July 29, 2009 (‘‘FSI
letter’’); letter from Joan Hinchman, National
Society of Compliance Professionals, to Elizabeth
M. Murphy, Secretary, Commission, dated July 29,
2009 (‘‘NSCP letter’’); letter from Clifford E. Kirsch
and Susan Krawczyk, Sutherland Asbill & Brennan
LLP, on behalf of the Committee of Annuity
Insurers, to Elizabeth M. Murphy, Secretary,
Commission, dated July 29, 2009 (‘‘Sutherland
letter’’); letter from Gary A. Sanders, National
Association of Insurance and Financial Advisors, to
Elizabeth M. Murphy, Secretary, Commission, dated
July 29, 2009 (‘‘NAIFA letter’’); letter from James
Livingston, National Planning Holdings, Inc., to
Elizabeth M. Murphy Secretary, Commission, dated
July 28, 2009 (‘‘NPH letter’’); and letter from
Stephanie L. Brown, LPL Financial Corporation, to
Elizabeth M. Murphy, Secretary, Commission, dated
August 6, 2009 (‘‘LPL letter’’).
3 See letter from Gary L. Goldsholle, FINRA, to
Elizabeth M. Murphy, Secretary, Commission, dated
July 30, 2010 (‘‘FINRA Response’’).
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II. Description of Proposed Rule Change
As part of the process of developing
a new consolidated rulebook
(‘‘Consolidated FINRA Rulebook’’),4
FINRA proposed to adopt NASD Rule
3030 (Outside Business Activities of an
Associated Person) as FINRA Rule 3270
(Outside Business Activities of
Registered Persons) in the Consolidated
FINRA Rulebook with moderate
changes. The proposed rule change
would delete NYSE Rule 3465
(Limitations—Employment and
Association with Members and Member
Organizations) and its interpretations.
However, as further described below,
the proposed rule change would
incorporate certain provisions of NYSE
Rule 346 into new FINRA Rule 3270.
Proposed FINRA Rule 3270 (Outside
Business Activities of Registered
Persons)
Proposed FINRA Rule 3270 would
prohibit any registered person from
being an employee, independent
contractor, sole proprietor, officer,
director or partner of another person, or
being compensated, or having the
reasonable expectation of compensation,
from another person as a result of any
business activity outside the scope of
the relationship with his or her member
firm, unless he or she has provided
prior written notice to the member. The
proposed rule change would expand the
obligations imposed under NASD Rule
3030, which prohibits any registered
person from being employed by or
accepting any compensation from any
person as a result of any outside
business activity, other than passive
investment, unless he has provided
prompt written notice to his member
firm. In contrast, NYSE Rule 346(b)
generally prohibits any member (as
defined in the NYSE rules) or employee
of a member organization from being
engaged in any other business, or being
employed or compensated by any other
person, or serving as an officer, director,
partner or employee of another business
organization or owning any stock or
having any direct or indirect financial
4 The current FINRA rulebook consists of (1)
FINRA Rules; (2) NASD Rules; and (3) rules
incorporated from NYSE (‘‘Incorporated NYSE
Rules’’) (together, the NASD Rules and Incorporated
NYSE Rules are referred to as the ‘‘Transitional
Rulebook’’). While the NASD Rules generally apply
to all FINRA members, the Incorporated NYSE
Rules apply only to those members of FINRA that
are also members of the NYSE (‘‘Dual Members’’).
The new FINRA Rules apply to all FINRA members,
unless such rules have a more limited application
by their terms. For more information about the
rulebook consolidation process, see FINRA
Information Notice, March 12, 2008 (Rulebook
Consolidation Process).
5 For convenience, the proposed rule change
refers to Incorporated NYSE Rules as NYSE Rules.
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interest in any other organization
engaged in any securities, financial or
kindred business unless such person
has made a written request to, and
received prior written consent from, his
or her member organization employer.
The primary difference between the
existing NASD and NYSE rules is the
timing of the required notice and the
requirement in the NYSE rule for a
member’s prior written consent. With
respect to timing, FINRA believes that
registered persons should not be
permitted to engage in outside business
activities without the firm’s prior
knowledge. Potential investor harm
could ensue in the interim period
between the time the registered person
commences an outside business activity
and the time a firm receives ‘‘prompt’’
written notice. Also, because the term
‘‘prompt’’ is susceptible to differing
interpretations, adopting a prior written
notice standard in this context would
promote consistency within the
securities industry, though FINRA
understands that, in practice, many
firms already require prior written
notice. Further, a prior written notice
standard would allow a firm an
opportunity to determine whether the
proposed outside business activity is
properly being characterized by the
registered representative as an outside
business activity, or whether it is an
outside securities activity, subject to
NASD Rule 3040 (Private Securities
Transactions of an Associated Person).6
For these reasons, FINRA proposed
that FINRA Rule 3270 require prior
written notice whenever a registered
representative will be an employee,
independent contractor, sole proprietor,
officer, director or partner of another
person, or will be compensated, or have
the reasonable expectation of
compensation, from any other person as
a result of any outside business activity.
With respect to the requirement in
NYSE Rule 346(b) for prior written
consent, FINRA believes that requiring
prior written consent for outside
business activities is unnecessary. To
the extent that these activities may
nevertheless raise investor protection
concerns and adversely impact the
individual’s business within the firm,
the proposed rule change has
supplementary material, drawn in part
from procedures required in NYSE Rule
6 FINRA is proposing to replace NASD Rule 3040
with new provisions in proposed FINRA Rule
3110(b)(3), as part of the consolidated FINRA rules
addressing supervision and supervisory controls.
See Notice of Filing of Proposed Rule Change to
Adopt FINRA Rules 2090 (Know Your Customer)
and 2111 (Suitability) in the Consolidated FINRA
Rulebook, Securities Exchange Act Release No.
62718 (August 13, 2010), 75 FR 51310 (August 19,
2010).
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346(e), that sets forth the obligations of
a member upon receipt of a written
notice of a proposed outside business
activity. Under the proposal as
amended, the supplementary material
states that, upon receiving written
notice under Rule 3270, a member must
consider whether the proposed activity
will: (1) Interfere with or otherwise
compromise the registered person’s
responsibilities to the member and/or
the member’s customers or (2) be
viewed by customers or the public as
part of the member’s business based
upon, among other factors, the nature of
the proposed activity and the manner in
which it will be offered. Based upon
this review, the member must evaluate
the advisability of imposing specific
conditions or limitations on a registered
person’s outside business activity,
including where circumstances warrant,
prohibiting the activity. A member also
must evaluate the proposed activity to
determine whether the activity properly
is characterized as an outside business
activity or whether it should be treated
as an outside securities activity subject
to the requirements of NASD Rule 3040.
A member must also keep a record of its
compliance with these obligations with
respect to each written notice received
and must preserve this record for the
period of time and accessibility
specified in Rule 17a-4(e)(1) under the
Securities Exchange Act of 1934.
The proposed rule change also
harmonizes and simplifies the standards
for what constitutes an outside business
activity. Currently, the NASD and NYSE
rules have a number of overlapping
provisions. NYSE Rule 346(b) generally
requires, subject to certain exceptions,
written notice whenever a member or
employee of a member organization is
employed or compensated by any other
person; serves as an officer, director,
partner or employee of another
organization; or owns any stock or has,
directly or indirectly, any financial
interest in any other organization
engaged in any securities, financial or
kindred business. NASD Rule 3030
generally requires notice whenever a
registered person is employed by or
accepts any compensation from any
person as a result of any outside
business activity, other than passive
investment. In reconciling these two
standards, the proposed rule change
requires prior written notice whenever a
registered representative will be an
employee, independent contractor, sole
proprietor, officer, director or partner of
another person, or will be compensated,
or have the reasonable expectation of
compensation, from any other person as
a result of any outside business activity.
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16:33 Aug 30, 2010
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The inclusion of the phrase ‘‘or have the
reasonable expectation of
compensation’’ addresses situations in
which an outside activity does not
immediately yield compensation (e.g.,
where a registered person intends to
work for a start-up business). FINRA
believes that a registered person should
not be able to engage in an activity in
which he or she reasonably expects to
be compensated without providing the
firm with prior written notice, and
FINRA believes that a rule dependent
on the prior receipt of compensation is
too narrow and may be susceptible to
abuse. Proposed Rule 3270 retains the
exemptions in NASD Rule 3030 for
‘‘passive investments’’ and activities
subject to the requirements of NASD
Rule 3040.7
In addition, the proposed rule would
streamline the text by replacing the
phrase ‘‘person associated with a
member in any registered capacity’’ with
‘‘registered person’’ and would re-title
the rule ‘‘Outside Business Activities of
Registered Persons’’ to better reflect its
application to registered persons.
Deleted Provisions of Incorporated
NYSE Rule 346 and Its Supplementary
Material and Interpretations
FINRA proposes to delete other
provisions of NYSE Rule 346 that are
unnecessary and/or duplicative of
provisions in the federal securities laws
or the FINRA Rulebook and delete
NYSE Rule Interpretations that are
unnecessary or inconsistent with
Proposed Rule 3270.
NYSE Rule 346(a) and related NYSE
Interpretation 346/01 require natural
persons not associated with entities that
are registered broker-dealers to register
with the Commission unless specifically
exempted by the Exchange Act. FINRA
has proposed to delete these provisions
as redundant in light of Section 15(a) of
the Exchange Act.8
NYSE Rule 346(c) provides that where
a member organization approves an
employee’s participation in a private
securities transaction in which regard
the employee has or may receive selling
compensation, the transaction shall be
recorded on the books and records of
the member organization, which shall
supervise such participation as if the
transaction were executed on its behalf.
FINRA has proposed to delete this
provision as redundant of NASD Rule
7 FINRA is separately considering NASD Rule
3050 (Transactions for or by Associated Persons) as
part of the rulebook consolidation process and will
consider whether transactions subject to NASD
Rule 3050, as proposed to be amended, also should
be exempted from proposed FINRA Rule 3270.
8 15 U.S.C. 78o–3.
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53363
3040 (Private Securities Transactions of
an Associated Person).9
NYSE Rule 346(d) provides that no
member shall qualify more than one
member organization for membership.
This provision is inconsistent with
FINRA’s approach to membership,
which allows the same individual to
qualify more than one firm for
membership, as appropriate. FINRA
examines separately the merits of each
membership application and has
proposed to delete the prohibition in the
NYSE rule.
NYSE Rule 346(e) requires every
employee of a member organization who
is assigned or delegated any
responsibility or authority pursuant to
NYSE Rule 342 to devote his entire time
during business hours to the business of
such member organization unless an
alternative arrangement has been
approved in writing by the member
organization. FINRA believes that the
existing and proposed rules on
supervision and outside business
activities adequately ensure that the
member firm’s business is not adversely
affected by outside activities. Moreover,
associated persons in the independent
broker-dealer channel at times devote
substantial time to non-member
business and this provision would
create unnecessary administrative
burdens if applied to them.
Accordingly, FINRA has proposed to
delete this provision.
NYSE 346(f) provides that unless
otherwise permitted by the Exchange,
no member, member organization,
approved person, employee or any
person directly or indirectly controlling,
controlled by or under common control
with a member or member organization
shall have associated with him or it any
person who is known, or in the exercise
of reasonable care should be known, to
be subject to any ‘‘statutory
disqualification’’ defined in Section
3(a)(39) of the Exchange Act.10 In
connection with FINRA’s consolidation
transaction, FINRA amended its
definition of disqualification in its ByLaws to align with the Exchange Act
definition, thereby incorporating
additional categories of statutory
disqualification, including certain
affiliated relationships.11 Accordingly,
FINRA has proposed to delete NYSE
Rule 346(f) as redundant.
Finally, FINRA has proposed to delete
NYSE Rule Interpretations 346/02 and
/03, which address personal business
9 See
supra note 6.
U.S.C. 78c(a)(39).
11 For further discussion, see Securities Exchange
Act Release No. 59586 (March 17, 2009), 74 FR
12166 (March 23, 2009) (Order Approving SR–
FINRA–2008–045).
10 15
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Federal Register / Vol. 75, No. 168 / Tuesday, August 31, 2010 / Notices
expenses and factors to consider when
approving outside activities, FINRA
believes the Interpretations are
unnecessary or inconsistent with
proposed FINRA Rule 3270. In
particular, the provisions in NYSE Rule
Interpretation 346/02 requiring a firm to
assume responsibility for all activities
effected on its behalf and under its
name are addressed by other FINRA
rules, including supervision rules. In
addition, FINRA has chosen not to
impose a requirement for firms to
approve all advertisements of an outside
business, although a firm may impose
such restrictions as part of its
obligations under supplementary
material .01. FINRA requires firms to
approve all advertisements for member
firm business, even if an advertisement
relates to the firm’s non-securities
business; however, FINRA does not
believe that approval should be required
for outside business activities permitted
under the proposed rule change.
For the reasons noted above, FINRA
has proposed to transfer NASD Rule
3030 into the Consolidated FINRA
Rulebook with the changes described
herein. In addition, FINRA has
proposed to delete NYSE Rule 346 and
its interpretations from the Transitional
Rulebook also as described herein.
III. Summary of Comments and
Amendment No. 1
srobinson on DSKHWCL6B1PROD with NOTICES
Prior Member Consent to Outside
Business Activities of Registered Persons
Certain commenters suggested that
FINRA amend proposed FINRA Rule
3270 to require a member’s consent
before a registered person may engage in
any outside business activity. One
commenter noted that in practice most
registered persons are required to get
written acknowledgement from their
firm prior to engaging in outside
business activities, and believes that
requiring member consent ensures that
the registered person does not engage in
an outside business activity before the
member completes its due diligence as
required under the proposed
Supplementary Material in proposed
FINRA Rule 3270.12 According to two
commenters, allowing a registered
person to engage in outside business
activities upon notice of the proposed
activity without a requirement that the
firm consent to such activity places the
firm in a position of risk during the
interim period since the firm may not
have had ample time to review the
matter.13 Certain commenters believed
the proposed rule should require an
12 NPH
letter.
13 FSI letter, LPL letter.
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16:33 Aug 30, 2010
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affirmative written response from the
member 14 or a written response noting
any objections or concerns to the
proposed activity.15 One commenter
supported the proposal not to
incorporate a member consent
requirement but notes that the
requirements of proposed
Supplementary Material .01 are the
functional equivalent of requiring prior
consent from the member.16
FINRA responded that it does not
plan to amend the proposal to
incorporate a prior member consent
requirement for a registered person’s
outside business activities as such a
requirement is not necessary for all
types of firms. FINRA noted that the
proposal does not preclude any member
from including a prior member consent
requirement as part of its procedures to
manage the outside business activities
of its registered persons.
‘‘Compensation’’ and ‘‘Reasonable
Expectation of Compensation’’
One commenter believed that the
‘‘reasonable expectation of
compensation’’ standard in proposed
FINRA Rule 3270 is too vague,
particularly if this initial determination
is made by the registered person, and
expressed concern that FINRA will
question the initial determinations
made by registered persons and/or their
supervisors.17 Another commenter
requested that FINRA define the term
‘‘compensation.’’ 18 FINRA, in its
response, stated that it believes that the
standards in the proposed rule are
appropriate and workable; that members
will demand sufficient information to
enable them to make the necessary
determinations; and that the
reasonableness of a determination will
not be judged in hindsight, but rather
based on the information requested and
obtained at the time of the registered
person’s prior written notice. Also in its
response, FINRA stated that it does not
intend to amend the proposal to adopt
a definition for the term ‘‘compensation’’
in the proposed rule. FINRA notes that
neither NASD Rule 3030 nor NYSE Rule
346, upon which the proposed rule
14 FSI
letter, LPL letter.
letter.
16 NAIFA letter.
17 Sutherland letter. This commenter requested
guidance on facts and circumstances that would be
relevant in making this initial determination. Also,
the commenter recommended that FINRA clarify
that the initial determination should be made by the
member, based on information provided by the
registered person, and that it would not be triggered
absent a concrete understanding or agreement
between the registered person and its outside
business that compensation will or will likely be
paid over time.
18 FSI letter.
15 NAIFA
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Frm 00094
Fmt 4703
Sfmt 4703
change is based, includes a definition of
the term ‘‘compensation,’’ and FINRA
believes that incorporating a definition
of this term in the proposed rule may
frustrate the intent and application of
the rule as it may encourage registered
persons to structure outside business
arrangements to purposefully evade the
requirements of the proposed rule.
Also, a commenter suggested
changing language in the general
requirement of proposed FINRA Rule
3270.19 The proposed rule provides that
‘‘[n]o registered person may be an
employee, independent contractor, sole
proprietor, officer, director or partner of
another person, or be compensated, or
have the reasonable expectation of
compensation from any other person as
a result of any business activity outside
the scope of the relationship with his or
her member.’’ The commenter requested
that the phrase ‘‘as a result of any
business activity’’ be replaced with ‘‘in
conjunction with an established
business enterprise.’’ The commenter
advocated a revised approach noting
that an individual is an employee,
officer or director in a business entity or
not, so it does not make sense to
connect these relationships to the
phrase ‘‘as a result of any business
activity.’’ In its response, FINRA notes
that the reference to ‘‘as a result of any
business activity’’ is from NASD Rule
3030 and has not been changed under
the proposal. FINRA states that the
phrase the compensation language
directly preceding it and, accordingly,
the proposed rule prohibits a registered
person from either acting in one of the
enumerated roles or from being
compensated by, or having the
reasonable expectation of compensation
from, any other person as a result of any
business activity outside the scope of
the relationship with his or her member
firm, unless he or she has provided
prior notice to the member. FINRA does
not intend to amend the proposal to
incorporate the suggested language.
Reporting Material Changes to Outside
Business Activities
A few commenters requested that the
proposed rule impose an ongoing
obligation on registered persons to
provide prior written notice to a
member should an outside business
activity undergo a material change.20
Two commenters noted that without
such a requirement, a member has no
way to make knowledgeable decisions
regarding these activities subjecting the
firm to regulatory risk and harm.21 One
19 FSI
letter.
letter, LPL letter, NPH letter.
21 FSI letter, LPL letter.
20 FSI
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srobinson on DSKHWCL6B1PROD with NOTICES
commenter requested clarification on a
member’s liability in the event an
outside business activity changes over
time.22 In its response, FINRA states
that it believes that the requirement for
a registered person to amend or
supplement the nature of the prior
written notice is implicit in the
proposed rule change. FINRA explains
that a registered person’s prior written
notice is valid only to the extent that it
continues to accurately describe the
outside business activity and, thus, it is
incumbent on the registered person to
provide prior written notice before
altering the nature of any outside
business activity previously disclosed in
writing to the firm. FINRA also notes
that a member’s supervisory system
should demand that each registered
person notify the member in the event
of a material change to his or her
outside business activities.
Supplementary Material .01
(Obligations of Member Receiving
Notice)
All of the comment letters received by
the Commission addressed proposed
Supplementary Material .01. The
Supplementary Material initially had
provided that firms must review the
registered person’s participation in the
outside activity to determine whether it
raises investor protection concerns. As
initially proposed, the Supplementary
Material would have required that a
member must make a determination as
to whether the proposed activity raises
investor protection concerns, and if so,
the firm must implement procedures or
restrictions on the activity to protect
investors, or prohibit the activity.
Certain commenters opposed the
proposed Supplementary Material, in
whole or in part, and request that it be
removed from the proposal.23
Generally, the commenters believed
that the proposal exceeds FINRA’s
jurisdiction by imposing on members a
supervisory obligation for the outside
business activities of its registered
persons.24 The commenters stated that
members do not have the resources to
supervise the wide variety of outside
business activities in which their
registered persons engage. One
commenter further provided that this
limited knowledge or expertise would
impede the determination of whether an
outside business activity raises investor
protection concerns.25 Certain other
commenters believed that the proposed
22 NSCP
23 FSI
letter.
letter, LPL letter, NAIFA letter, Sutherland
letter.
24 FSI letter, LPL letter, NAIFA letter, NPH letter,
NSCP letter, Sutherland letter.
25 NPH letter.
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Supplementary Material would distract
members from core supervisory
functions by requiring supervision of
activities beyond their purview or
practical control.26
Certain commenters suggested that
FINRA clarify the due diligence
required in making a determination
whether a proposed outside business
activity raises ‘‘investor protection
concerns’’ 27 and, further, how FINRA
would define the terms ‘‘investor,’’
‘‘protect investors’’ and ‘‘investor
protection concerns’’ for purposes of the
proposed rule.28 One commenter noted
that the term ‘‘investor protection
concerns’’ could be subject to
interpretation and applied differently
across member firms.29 Another
commenter stated that almost any
activity could raise investor protection
concerns and suggests that, unless this
term is defined as it relates to nonsecurities activities, FINRA should
remove it from the proposal.30 One
commenter believed the Supplementary
Material, as initially proposed, was
overly broad because many outside
business activities have nothing to do
with traditional investors or investor
protection issues.31
In response to the comments received
by the Commission, FINRA is amending
proposed Supplementary Material .01.
Under the Supplementary Material, as
amended, FINRA will expect members
to assess the impact of the outside
activity on the member’s business and
the member’s customers, as well as the
extent to which customers or the public
would perceive the outside activity to
be part of the member’s business.
Specifically, the revised proposal
provides that, upon receipt of a written
notice under proposed FINRA Rule
3270, a member shall consider whether
the proposed activity will: (1) Interfere
with or otherwise compromise the
registered person’s responsibilities to
the member and/or the member’s
customers or (2) be viewed by customers
or the public as part of the member’s
business based upon, among other
factors, the nature of the proposed
activity and the manner in which it will
be offered. Additionally, based on the
member’s review of such factors, the
member would be required to evaluate
the advisability of imposing specific
conditions or limitations on a registered
person’s outside business activity,
26 FSI
letter, NAIFA letter.
letter, NPH letter, NSCP letter.
28 FSI letter, NSCP letter, Sutherland letter.
29 LPL letter.
30 NSCP letter.
31 Sutherland letter.
27 LPL
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53365
including where circumstances warrant,
prohibiting the activity.
IV. Discussion and Finding
After careful review, the Commission
finds that the proposed rule change is
consistent with the requirements of the
Act and the rules and regulations
thereunder applicable to a national
securities association.32 The
Commission believes that the proposed
rule change, as amended, is consistent
with the provisions of Section 15A(b)(6)
of the Act, which requires, among other
things, that FINRA rules must be
designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, and, in general, to protect
investors and the public interest.33 The
proposed rule change will clarify and
streamline NASD Rule 3030 for
adoption as a FINRA rule in the new
Consolidated FINRA Rulebook, while
also implementing additional
protections such as the need for
registered persons to provide prior
written notice to its member firms of
proposed outside business activities and
for firms to implement a system to
assess the risk that these outside
business activities may cause potential
harm to investors and to manage these
risks by taking appropriate actions as
prescribed by the proposed rule.
V. Accelerated Approval
The Commission finds good cause,
pursuant to Section 19(b)(2) of the
Act,34 for approving the proposed rule
change, as amended by Amendment No.
1 thereto, prior to the 30th day after the
date of publication in the Federal
Register. The changes proposed in
Amendment No. 1 do not raise novel
regulatory concerns. Moreover,
accelerating approval of this proposal
should benefit FINRA member firms
and investors by streamlining and
clarifying a member’s obligations upon
receipt of notice of a proposed outside
business activity by a registered person.
VI. 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:
32 In approving the proposed rule change, the
Commission has considered the rule change’s
impact on efficiency, competition, and capital
formation. 15 U.S.C. 78c(f).
33 See 15 U.S.C. 78o–3(b)(6).
34 15 U.S.C. 78s(b)(2).
E:\FR\FM\31AUN1.SGM
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53366
Federal Register / Vol. 75, No. 168 / Tuesday, August 31, 2010 / Notices
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
Number SR–FINRA–2009–042 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–FINRA–2009–042. 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 Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal office of
FINRA. 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–FINRA–2009–042 and
should be submitted on or before
September 21, 2010.
srobinson on DSKHWCL6B1PROD with NOTICES
VII. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,35 that the
proposed rule change (SR–FINRA–
2009–042), as amended, be, and hereby
is, approved on an accelerated basis.
35 15
U.S.C. 78s(b)(2).
VerDate Mar<15>2010
16:33 Aug 30, 2010
Jkt 220001
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.36
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010–21606 Filed 8–30–10; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–62763; File Nos. SR–BATS–
2010–018; SR–BX–2010–044; SR–CBOE–
2010–065; SR–CHX–2010–14; SR–EDGA–
2010–05; SR–EDGX–2010–05; SR–FINRA–
2010–033; SR–ISE–2010–66; SR–NYSE–
2010–49; SR–NYSEAmex–2010–63; SR–
NYSEArca–2010–61; SR–NASDAQ–2010–
079; SR–NSX–2010–08]
Self-Regulatory Organizations; BATS
Exchange, Inc.; Chicago Board
Options Exchange, Incorporated;
Chicago Stock Exchange, Inc.; EDGA
Exchange, Inc.; EDGX Exchange, Inc.;
Financial Industry Regulatory
Authority, Inc.; International Securities
Exchange LLC; NASDAQ OMX BX,
Inc.; The NASDAQ Stock Market LLC;
National Stock Exchange, Inc.; New
York Stock Exchange LLC; NYSE
Amex LLC; NYSE Arca, Inc.; Notice of
Designation of Longer Period for
Commission Action on Proposed Rule
Changes Relating to Trading Pauses
Due to Extraordinary Market Volatility
August 24, 2010.
On June 30, 2010, each of BATS
Exchange, Inc., Chicago Board Options
Exchange, Incorporated, Chicago Stock
Exchange, Inc., EDGA Exchange, Inc.,
EDGX Exchange, Inc., Financial
Industry Regulatory Authority, Inc.,
International Securities Exchange, LLC,
The NASDAQ Stock Market LLC,
NASDAQ OMX BX, Inc., National Stock
Exchange, Inc., New York Stock
Exchange LLC, NYSE Amex LLC, and
NYSE Arca, Inc. filed with the
Securities and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) 1 of the Securities Exchange Act
of 1934 (‘‘Act’’),2 and Rule 19b–4
thereunder,3 proposed rule changes to
amend certain of their respective rules
to add securities to the single-stock
circuit breaker pilot program.4
Section 19(b)(2) of the Act 5 provides
that, within thirty-five days of the
36 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
4 The single-stock circuit breaker pilot program
was initially approved on June 10, 2010. See
Securities Exchange Act Release Nos. 62251 (June
10, 2010), 75 FR 34183 (June 16, 2010); 62252 (June
10, 2010), 75 FR 34186 (June 16, 2010).
5 15 U.S.C. 78s(b)(2).
1 15
PO 00000
Frm 00096
Fmt 4703
Sfmt 4703
publication of notice of the filing of a
proposed rule change, or within such
longer period as the Commission may
designate up to ninety days of such date
if it finds such longer period to be
appropriate and publishes its reasons
for so finding, the Commission shall
either approve the proposed rule change
or institute proceedings to determine
whether the proposed rule change
should be disapproved. The
Commission extended this time period
from August 11, 2010 to August 25,
2010.6 The Commission is again
extending this time period.
The Commission finds it appropriate
to designate a longer period within
which to take action on the proposed
rule changes so that it has sufficient
time to consider these proposed rule
changes, which relate to the addition of
securities to the single-stock circuit
breaker pilot program, and issues raised
in the comment letters that have been
submitted in connection with these
filings.
Accordingly, the Commission,
pursuant to Section 19(b)(2) of the Act,7
designates September 10, 2010, as the
date by which the Commission should
either approve or institute proceedings
to determine whether to disapprove the
proposed rule changes.
By the Commission.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010–21630 Filed 8–30–10; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–62766; File No. SR–Phlx–
2010–117]
Self-Regulatory Organizations;
NASDAQ OMX PHLX, Inc.; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Relating to
Routing Fees, the Monthly Cap and
Electronic Auctions
August 25, 2010.
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 August
23, 2010, NASDAQ OMX PHLX, Inc.
(‘‘Phlx’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
6 See Securities Exchange Act Release No.
62688A (August 11, 2010), 75 FR 51138 (August 18,
2010).
7 15 U.S.C. 78s(b)(2).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
E:\FR\FM\31AUN1.SGM
31AUN1
Agencies
[Federal Register Volume 75, Number 168 (Tuesday, August 31, 2010)]
[Notices]
[Pages 53362-53366]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-21606]
[[Page 53362]]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-62762; File No. SR-FINRA-2009-042]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of Amendment No. 1 and Order Granting
Accelerated Approval of a Proposed Rule Change, as Modified by
Amendment No. 1, Relating to Outside Business Activities of Registered
Persons
August 23, 2010.
On June 8, 2009, Financial Industry Regulatory Authority, Inc.
(``FINRA'') (f/k/a National Association of Securities Dealers, Inc.
(``NASD'')) filed with the Securities and Exchange Commission (``SEC''
or ``Commission'') a proposed rule change relating to the outside
business activities of registered persons. FINRA proposed to adopt NASD
Rule 3030 (Outside Business Activities of an Associated Person) as
FINRA Rule 3270 (Outside Business Activities of Registered Persons) in
the consolidated FINRA rulebook with moderate changes. The proposed
rule change would delete Incorporated NYSE Rule 346 (Limitations--
Employment and Association with Members and Member Organizations) and
its interpretations.
The proposed rule change was published for comment in the Federal
Register on July 8, 2009.\1\ The Commission received six comments on
the proposed rule change.\2\ On July 30, 2010, FINRA responded to the
comments.\3\ Also on July 30, 2010, FINRA filed Amendment No. 1 to the
proposed rule change.
---------------------------------------------------------------------------
\1\ See Securities Exchange Act Release No. 60199 (June 30,
2009), 74 FR 32668 (July 8, 2009).
\2\ See letter from Dale E. Brown, CAE, Financial Services
Institute, to Elizabeth M. Murphy, Secretary, Commission, dated July
29, 2009 (``FSI letter''); letter from Joan Hinchman, National
Society of Compliance Professionals, to Elizabeth M. Murphy,
Secretary, Commission, dated July 29, 2009 (``NSCP letter''); letter
from Clifford E. Kirsch and Susan Krawczyk, Sutherland Asbill &
Brennan LLP, on behalf of the Committee of Annuity Insurers, to
Elizabeth M. Murphy, Secretary, Commission, dated July 29, 2009
(``Sutherland letter''); letter from Gary A. Sanders, National
Association of Insurance and Financial Advisors, to Elizabeth M.
Murphy, Secretary, Commission, dated July 29, 2009 (``NAIFA
letter''); letter from James Livingston, National Planning Holdings,
Inc., to Elizabeth M. Murphy Secretary, Commission, dated July 28,
2009 (``NPH letter''); and letter from Stephanie L. Brown, LPL
Financial Corporation, to Elizabeth M. Murphy, Secretary,
Commission, dated August 6, 2009 (``LPL letter'').
\3\ See letter from Gary L. Goldsholle, FINRA, to Elizabeth M.
Murphy, Secretary, Commission, dated July 30, 2010 (``FINRA
Response'').
---------------------------------------------------------------------------
II. Description of Proposed Rule Change
As part of the process of developing a new consolidated rulebook
(``Consolidated FINRA Rulebook''),\4\ FINRA proposed to adopt NASD Rule
3030 (Outside Business Activities of an Associated Person) as FINRA
Rule 3270 (Outside Business Activities of Registered Persons) in the
Consolidated FINRA Rulebook with moderate changes. The proposed rule
change would delete NYSE Rule 346\5\ (Limitations--Employment and
Association with Members and Member Organizations) and its
interpretations. However, as further described below, the proposed rule
change would incorporate certain provisions of NYSE Rule 346 into new
FINRA Rule 3270.
---------------------------------------------------------------------------
\4\ The current FINRA rulebook consists of (1) FINRA Rules; (2)
NASD Rules; and (3) rules incorporated from NYSE (``Incorporated
NYSE Rules'') (together, the NASD Rules and Incorporated NYSE Rules
are referred to as the ``Transitional Rulebook''). While the NASD
Rules generally apply to all FINRA members, the Incorporated NYSE
Rules apply only to those members of FINRA that are also members of
the NYSE (``Dual Members''). The new FINRA Rules apply to all FINRA
members, unless such rules have a more limited application by their
terms. For more information about the rulebook consolidation
process, see FINRA Information Notice, March 12, 2008 (Rulebook
Consolidation Process).
\5\ For convenience, the proposed rule change refers to
Incorporated NYSE Rules as NYSE Rules.
---------------------------------------------------------------------------
Proposed FINRA Rule 3270 (Outside Business Activities of Registered
Persons)
Proposed FINRA Rule 3270 would prohibit any registered person from
being an employee, independent contractor, sole proprietor, officer,
director or partner of another person, or being compensated, or having
the reasonable expectation of compensation, from another person as a
result of any business activity outside the scope of the relationship
with his or her member firm, unless he or she has provided prior
written notice to the member. The proposed rule change would expand the
obligations imposed under NASD Rule 3030, which prohibits any
registered person from being employed by or accepting any compensation
from any person as a result of any outside business activity, other
than passive investment, unless he has provided prompt written notice
to his member firm. In contrast, NYSE Rule 346(b) generally prohibits
any member (as defined in the NYSE rules) or employee of a member
organization from being engaged in any other business, or being
employed or compensated by any other person, or serving as an officer,
director, partner or employee of another business organization or
owning any stock or having any direct or indirect financial interest in
any other organization engaged in any securities, financial or kindred
business unless such person has made a written request to, and received
prior written consent from, his or her member organization employer.
The primary difference between the existing NASD and NYSE rules is
the timing of the required notice and the requirement in the NYSE rule
for a member's prior written consent. With respect to timing, FINRA
believes that registered persons should not be permitted to engage in
outside business activities without the firm's prior knowledge.
Potential investor harm could ensue in the interim period between the
time the registered person commences an outside business activity and
the time a firm receives ``prompt'' written notice. Also, because the
term ``prompt'' is susceptible to differing interpretations, adopting a
prior written notice standard in this context would promote consistency
within the securities industry, though FINRA understands that, in
practice, many firms already require prior written notice. Further, a
prior written notice standard would allow a firm an opportunity to
determine whether the proposed outside business activity is properly
being characterized by the registered representative as an outside
business activity, or whether it is an outside securities activity,
subject to NASD Rule 3040 (Private Securities Transactions of an
Associated Person).\6\
---------------------------------------------------------------------------
\6\ FINRA is proposing to replace NASD Rule 3040 with new
provisions in proposed FINRA Rule 3110(b)(3), as part of the
consolidated FINRA rules addressing supervision and supervisory
controls. See Notice of Filing of Proposed Rule Change to Adopt
FINRA Rules 2090 (Know Your Customer) and 2111 (Suitability) in the
Consolidated FINRA Rulebook, Securities Exchange Act Release No.
62718 (August 13, 2010), 75 FR 51310 (August 19, 2010).
---------------------------------------------------------------------------
For these reasons, FINRA proposed that FINRA Rule 3270 require
prior written notice whenever a registered representative will be an
employee, independent contractor, sole proprietor, officer, director or
partner of another person, or will be compensated, or have the
reasonable expectation of compensation, from any other person as a
result of any outside business activity.
With respect to the requirement in NYSE Rule 346(b) for prior
written consent, FINRA believes that requiring prior written consent
for outside business activities is unnecessary. To the extent that
these activities may nevertheless raise investor protection concerns
and adversely impact the individual's business within the firm, the
proposed rule change has supplementary material, drawn in part from
procedures required in NYSE Rule
[[Page 53363]]
346(e), that sets forth the obligations of a member upon receipt of a
written notice of a proposed outside business activity. Under the
proposal as amended, the supplementary material states that, upon
receiving written notice under Rule 3270, a member must consider
whether the proposed activity will: (1) Interfere with or otherwise
compromise the registered person's responsibilities to the member and/
or the member's customers or (2) be viewed by customers or the public
as part of the member's business based upon, among other factors, the
nature of the proposed activity and the manner in which it will be
offered. Based upon this review, the member must evaluate the
advisability of imposing specific conditions or limitations on a
registered person's outside business activity, including where
circumstances warrant, prohibiting the activity. A member also must
evaluate the proposed activity to determine whether the activity
properly is characterized as an outside business activity or whether it
should be treated as an outside securities activity subject to the
requirements of NASD Rule 3040. A member must also keep a record of its
compliance with these obligations with respect to each written notice
received and must preserve this record for the period of time and
accessibility specified in Rule 17a-4(e)(1) under the Securities
Exchange Act of 1934.
The proposed rule change also harmonizes and simplifies the
standards for what constitutes an outside business activity. Currently,
the NASD and NYSE rules have a number of overlapping provisions. NYSE
Rule 346(b) generally requires, subject to certain exceptions, written
notice whenever a member or employee of a member organization is
employed or compensated by any other person; serves as an officer,
director, partner or employee of another organization; or owns any
stock or has, directly or indirectly, any financial interest in any
other organization engaged in any securities, financial or kindred
business. NASD Rule 3030 generally requires notice whenever a
registered person is employed by or accepts any compensation from any
person as a result of any outside business activity, other than passive
investment. In reconciling these two standards, the proposed rule
change requires prior written notice whenever a registered
representative will be an employee, independent contractor, sole
proprietor, officer, director or partner of another person, or will be
compensated, or have the reasonable expectation of compensation, from
any other person as a result of any outside business activity. The
inclusion of the phrase ``or have the reasonable expectation of
compensation'' addresses situations in which an outside activity does
not immediately yield compensation (e.g., where a registered person
intends to work for a start-up business). FINRA believes that a
registered person should not be able to engage in an activity in which
he or she reasonably expects to be compensated without providing the
firm with prior written notice, and FINRA believes that a rule
dependent on the prior receipt of compensation is too narrow and may be
susceptible to abuse. Proposed Rule 3270 retains the exemptions in NASD
Rule 3030 for ``passive investments'' and activities subject to the
requirements of NASD Rule 3040.\7\
---------------------------------------------------------------------------
\7\ FINRA is separately considering NASD Rule 3050 (Transactions
for or by Associated Persons) as part of the rulebook consolidation
process and will consider whether transactions subject to NASD Rule
3050, as proposed to be amended, also should be exempted from
proposed FINRA Rule 3270.
---------------------------------------------------------------------------
In addition, the proposed rule would streamline the text by
replacing the phrase ``person associated with a member in any
registered capacity'' with ``registered person'' and would re-title the
rule ``Outside Business Activities of Registered Persons'' to better
reflect its application to registered persons.
Deleted Provisions of Incorporated NYSE Rule 346 and Its Supplementary
Material and Interpretations
FINRA proposes to delete other provisions of NYSE Rule 346 that are
unnecessary and/or duplicative of provisions in the federal securities
laws or the FINRA Rulebook and delete NYSE Rule Interpretations that
are unnecessary or inconsistent with Proposed Rule 3270.
NYSE Rule 346(a) and related NYSE Interpretation 346/01 require
natural persons not associated with entities that are registered
broker-dealers to register with the Commission unless specifically
exempted by the Exchange Act. FINRA has proposed to delete these
provisions as redundant in light of Section 15(a) of the Exchange
Act.\8\
---------------------------------------------------------------------------
\8\ 15 U.S.C. 78o-3.
---------------------------------------------------------------------------
NYSE Rule 346(c) provides that where a member organization approves
an employee's participation in a private securities transaction in
which regard the employee has or may receive selling compensation, the
transaction shall be recorded on the books and records of the member
organization, which shall supervise such participation as if the
transaction were executed on its behalf. FINRA has proposed to delete
this provision as redundant of NASD Rule 3040 (Private Securities
Transactions of an Associated Person).\9\
---------------------------------------------------------------------------
\9\ See supra note 6.
---------------------------------------------------------------------------
NYSE Rule 346(d) provides that no member shall qualify more than
one member organization for membership. This provision is inconsistent
with FINRA's approach to membership, which allows the same individual
to qualify more than one firm for membership, as appropriate. FINRA
examines separately the merits of each membership application and has
proposed to delete the prohibition in the NYSE rule.
NYSE Rule 346(e) requires every employee of a member organization
who is assigned or delegated any responsibility or authority pursuant
to NYSE Rule 342 to devote his entire time during business hours to the
business of such member organization unless an alternative arrangement
has been approved in writing by the member organization. FINRA believes
that the existing and proposed rules on supervision and outside
business activities adequately ensure that the member firm's business
is not adversely affected by outside activities. Moreover, associated
persons in the independent broker-dealer channel at times devote
substantial time to non-member business and this provision would create
unnecessary administrative burdens if applied to them. Accordingly,
FINRA has proposed to delete this provision.
NYSE 346(f) provides that unless otherwise permitted by the
Exchange, no member, member organization, approved person, employee or
any person directly or indirectly controlling, controlled by or under
common control with a member or member organization shall have
associated with him or it any person who is known, or in the exercise
of reasonable care should be known, to be subject to any ``statutory
disqualification'' defined in Section 3(a)(39) of the Exchange Act.\10\
In connection with FINRA's consolidation transaction, FINRA amended its
definition of disqualification in its By-Laws to align with the
Exchange Act definition, thereby incorporating additional categories of
statutory disqualification, including certain affiliated
relationships.\11\ Accordingly, FINRA has proposed to delete NYSE Rule
346(f) as redundant.
---------------------------------------------------------------------------
\10\ 15 U.S.C. 78c(a)(39).
\11\ For further discussion, see Securities Exchange Act Release
No. 59586 (March 17, 2009), 74 FR 12166 (March 23, 2009) (Order
Approving SR-FINRA-2008-045).
---------------------------------------------------------------------------
Finally, FINRA has proposed to delete NYSE Rule Interpretations
346/02 and /03, which address personal business
[[Page 53364]]
expenses and factors to consider when approving outside activities,
FINRA believes the Interpretations are unnecessary or inconsistent with
proposed FINRA Rule 3270. In particular, the provisions in NYSE Rule
Interpretation 346/02 requiring a firm to assume responsibility for all
activities effected on its behalf and under its name are addressed by
other FINRA rules, including supervision rules. In addition, FINRA has
chosen not to impose a requirement for firms to approve all
advertisements of an outside business, although a firm may impose such
restrictions as part of its obligations under supplementary material
.01. FINRA requires firms to approve all advertisements for member firm
business, even if an advertisement relates to the firm's non-securities
business; however, FINRA does not believe that approval should be
required for outside business activities permitted under the proposed
rule change.
For the reasons noted above, FINRA has proposed to transfer NASD
Rule 3030 into the Consolidated FINRA Rulebook with the changes
described herein. In addition, FINRA has proposed to delete NYSE Rule
346 and its interpretations from the Transitional Rulebook also as
described herein.
III. Summary of Comments and Amendment No. 1
Prior Member Consent to Outside Business Activities of Registered
Persons
Certain commenters suggested that FINRA amend proposed FINRA Rule
3270 to require a member's consent before a registered person may
engage in any outside business activity. One commenter noted that in
practice most registered persons are required to get written
acknowledgement from their firm prior to engaging in outside business
activities, and believes that requiring member consent ensures that the
registered person does not engage in an outside business activity
before the member completes its due diligence as required under the
proposed Supplementary Material in proposed FINRA Rule 3270.\12\
According to two commenters, allowing a registered person to engage in
outside business activities upon notice of the proposed activity
without a requirement that the firm consent to such activity places the
firm in a position of risk during the interim period since the firm may
not have had ample time to review the matter.\13\ Certain commenters
believed the proposed rule should require an affirmative written
response from the member \14\ or a written response noting any
objections or concerns to the proposed activity.\15\ One commenter
supported the proposal not to incorporate a member consent requirement
but notes that the requirements of proposed Supplementary Material .01
are the functional equivalent of requiring prior consent from the
member.\16\
---------------------------------------------------------------------------
\12\ NPH letter.
\13\ FSI letter, LPL letter.
\14\ FSI letter, LPL letter.
\15\ NAIFA letter.
\16\ NAIFA letter.
---------------------------------------------------------------------------
FINRA responded that it does not plan to amend the proposal to
incorporate a prior member consent requirement for a registered
person's outside business activities as such a requirement is not
necessary for all types of firms. FINRA noted that the proposal does
not preclude any member from including a prior member consent
requirement as part of its procedures to manage the outside business
activities of its registered persons.
``Compensation'' and ``Reasonable Expectation of Compensation''
One commenter believed that the ``reasonable expectation of
compensation'' standard in proposed FINRA Rule 3270 is too vague,
particularly if this initial determination is made by the registered
person, and expressed concern that FINRA will question the initial
determinations made by registered persons and/or their supervisors.\17\
Another commenter requested that FINRA define the term
``compensation.'' \18\ FINRA, in its response, stated that it believes
that the standards in the proposed rule are appropriate and workable;
that members will demand sufficient information to enable them to make
the necessary determinations; and that the reasonableness of a
determination will not be judged in hindsight, but rather based on the
information requested and obtained at the time of the registered
person's prior written notice. Also in its response, FINRA stated that
it does not intend to amend the proposal to adopt a definition for the
term ``compensation'' in the proposed rule. FINRA notes that neither
NASD Rule 3030 nor NYSE Rule 346, upon which the proposed rule change
is based, includes a definition of the term ``compensation,'' and FINRA
believes that incorporating a definition of this term in the proposed
rule may frustrate the intent and application of the rule as it may
encourage registered persons to structure outside business arrangements
to purposefully evade the requirements of the proposed rule.
---------------------------------------------------------------------------
\17\ Sutherland letter. This commenter requested guidance on
facts and circumstances that would be relevant in making this
initial determination. Also, the commenter recommended that FINRA
clarify that the initial determination should be made by the member,
based on information provided by the registered person, and that it
would not be triggered absent a concrete understanding or agreement
between the registered person and its outside business that
compensation will or will likely be paid over time.
\18\ FSI letter.
---------------------------------------------------------------------------
Also, a commenter suggested changing language in the general
requirement of proposed FINRA Rule 3270.\19\ The proposed rule provides
that ``[n]o registered person may be an employee, independent
contractor, sole proprietor, officer, director or partner of another
person, or be compensated, or have the reasonable expectation of
compensation from any other person as a result of any business activity
outside the scope of the relationship with his or her member.'' The
commenter requested that the phrase ``as a result of any business
activity'' be replaced with ``in conjunction with an established
business enterprise.'' The commenter advocated a revised approach
noting that an individual is an employee, officer or director in a
business entity or not, so it does not make sense to connect these
relationships to the phrase ``as a result of any business activity.''
In its response, FINRA notes that the reference to ``as a result of any
business activity'' is from NASD Rule 3030 and has not been changed
under the proposal. FINRA states that the phrase the compensation
language directly preceding it and, accordingly, the proposed rule
prohibits a registered person from either acting in one of the
enumerated roles or from being compensated by, or having the reasonable
expectation of compensation from, any other person as a result of any
business activity outside the scope of the relationship with his or her
member firm, unless he or she has provided prior notice to the member.
FINRA does not intend to amend the proposal to incorporate the
suggested language.
---------------------------------------------------------------------------
\19\ FSI letter.
---------------------------------------------------------------------------
Reporting Material Changes to Outside Business Activities
A few commenters requested that the proposed rule impose an ongoing
obligation on registered persons to provide prior written notice to a
member should an outside business activity undergo a material
change.\20\ Two commenters noted that without such a requirement, a
member has no way to make knowledgeable decisions regarding these
activities subjecting the firm to regulatory risk and harm.\21\ One
[[Page 53365]]
commenter requested clarification on a member's liability in the event
an outside business activity changes over time.\22\ In its response,
FINRA states that it believes that the requirement for a registered
person to amend or supplement the nature of the prior written notice is
implicit in the proposed rule change. FINRA explains that a registered
person's prior written notice is valid only to the extent that it
continues to accurately describe the outside business activity and,
thus, it is incumbent on the registered person to provide prior written
notice before altering the nature of any outside business activity
previously disclosed in writing to the firm. FINRA also notes that a
member's supervisory system should demand that each registered person
notify the member in the event of a material change to his or her
outside business activities.
---------------------------------------------------------------------------
\20\ FSI letter, LPL letter, NPH letter.
\21\ FSI letter, LPL letter.
\22\ NSCP letter.
---------------------------------------------------------------------------
Supplementary Material .01 (Obligations of Member Receiving Notice)
All of the comment letters received by the Commission addressed
proposed Supplementary Material .01. The Supplementary Material
initially had provided that firms must review the registered person's
participation in the outside activity to determine whether it raises
investor protection concerns. As initially proposed, the Supplementary
Material would have required that a member must make a determination as
to whether the proposed activity raises investor protection concerns,
and if so, the firm must implement procedures or restrictions on the
activity to protect investors, or prohibit the activity. Certain
commenters opposed the proposed Supplementary Material, in whole or in
part, and request that it be removed from the proposal.\23\
---------------------------------------------------------------------------
\23\ FSI letter, LPL letter, NAIFA letter, Sutherland letter.
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Generally, the commenters believed that the proposal exceeds
FINRA's jurisdiction by imposing on members a supervisory obligation
for the outside business activities of its registered persons.\24\ The
commenters stated that members do not have the resources to supervise
the wide variety of outside business activities in which their
registered persons engage. One commenter further provided that this
limited knowledge or expertise would impede the determination of
whether an outside business activity raises investor protection
concerns.\25\ Certain other commenters believed that the proposed
Supplementary Material would distract members from core supervisory
functions by requiring supervision of activities beyond their purview
or practical control.\26\
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\24\ FSI letter, LPL letter, NAIFA letter, NPH letter, NSCP
letter, Sutherland letter.
\25\ NPH letter.
\26\ FSI letter, NAIFA letter.
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Certain commenters suggested that FINRA clarify the due diligence
required in making a determination whether a proposed outside business
activity raises ``investor protection concerns'' \27\ and, further, how
FINRA would define the terms ``investor,'' ``protect investors'' and
``investor protection concerns'' for purposes of the proposed rule.\28\
One commenter noted that the term ``investor protection concerns''
could be subject to interpretation and applied differently across
member firms.\29\ Another commenter stated that almost any activity
could raise investor protection concerns and suggests that, unless this
term is defined as it relates to non-securities activities, FINRA
should remove it from the proposal.\30\ One commenter believed the
Supplementary Material, as initially proposed, was overly broad because
many outside business activities have nothing to do with traditional
investors or investor protection issues.\31\
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\27\ LPL letter, NPH letter, NSCP letter.
\28\ FSI letter, NSCP letter, Sutherland letter.
\29\ LPL letter.
\30\ NSCP letter.
\31\ Sutherland letter.
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In response to the comments received by the Commission, FINRA is
amending proposed Supplementary Material .01. Under the Supplementary
Material, as amended, FINRA will expect members to assess the impact of
the outside activity on the member's business and the member's
customers, as well as the extent to which customers or the public would
perceive the outside activity to be part of the member's business.
Specifically, the revised proposal provides that, upon receipt of a
written notice under proposed FINRA Rule 3270, a member shall consider
whether the proposed activity will: (1) Interfere with or otherwise
compromise the registered person's responsibilities to the member and/
or the member's customers or (2) be viewed by customers or the public
as part of the member's business based upon, among other factors, the
nature of the proposed activity and the manner in which it will be
offered. Additionally, based on the member's review of such factors,
the member would be required to evaluate the advisability of imposing
specific conditions or limitations on a registered person's outside
business activity, including where circumstances warrant, prohibiting
the activity.
IV. Discussion and Finding
After careful review, the Commission finds that the proposed rule
change is consistent with the requirements of the Act and the rules and
regulations thereunder applicable to a national securities
association.\32\ The Commission believes that the proposed rule change,
as amended, is consistent with the provisions of Section 15A(b)(6) of
the Act, which requires, among other things, that FINRA rules must be
designed to prevent fraudulent and manipulative acts and practices, to
promote just and equitable principles of trade, and, in general, to
protect investors and the public interest.\33\ The proposed rule change
will clarify and streamline NASD Rule 3030 for adoption as a FINRA rule
in the new Consolidated FINRA Rulebook, while also implementing
additional protections such as the need for registered persons to
provide prior written notice to its member firms of proposed outside
business activities and for firms to implement a system to assess the
risk that these outside business activities may cause potential harm to
investors and to manage these risks by taking appropriate actions as
prescribed by the proposed rule.
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\32\ In approving the proposed rule change, the Commission has
considered the rule change's impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
\33\ See 15 U.S.C. 78o-3(b)(6).
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V. Accelerated Approval
The Commission finds good cause, pursuant to Section 19(b)(2) of
the Act,\34\ for approving the proposed rule change, as amended by
Amendment No. 1 thereto, prior to the 30th day after the date of
publication in the Federal Register. The changes proposed in Amendment
No. 1 do not raise novel regulatory concerns. Moreover, accelerating
approval of this proposal should benefit FINRA member firms and
investors by streamlining and clarifying a member's obligations upon
receipt of notice of a proposed outside business activity by a
registered person.
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\34\ 15 U.S.C. 78s(b)(2).
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VI. 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:
[[Page 53366]]
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number SR-FINRA-2009-042 on the subject line.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number SR-FINRA-2009-042. 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 Web site
viewing and printing in the Commission's Public Reference Room, 100 F
Street, NE., Washington, DC 20549, on official business days between
the hours of 10 a.m. and 3 p.m. Copies of such filing also will be
available for inspection and copying at the principal office of FINRA.
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-FINRA-2009-042
and should be submitted on or before September 21, 2010.
VII. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\35\ that the proposed rule change (SR-FINRA-2009-042), as amended,
be, and hereby is, approved on an accelerated basis.
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\35\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\36\
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\36\ 17 CFR 200.30-3(a)(12).
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Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010-21606 Filed 8-30-10; 8:45 am]
BILLING CODE 8010-01-P