Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of Amendment Nos. 1 and 2, and Order Granting Accelerated Approval of a Proposed Rule Change, as Modified by Amendment Nos. 1 and 2, Relating to FINRA Rule 8210 (Provision of Information and Testimony and Inspection and Copying of Books), 74253-74258 [2012-30049]
Download as PDF
Federal Register / Vol. 77, No. 240 / Thursday, December 13, 2012 / Notices
of reasonable dues, fees and other
charges among Exchange members and
other persons using its facilities. The
proposed rule change will allow the
Exchange and its market makers to
better compete for order flow since the
Exchange will now collect the same
amount of fee as PHLX in options
classes that are subject to the PFOF fee.
The Exchange believes that with this
proposed rule change, market makers
will have greater incentive to trade on
ISE in the symbols that are subject to the
PFOF fee and thus enhance
competition.
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.
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.
srobinson on DSK4SPTVN1PROD with
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 7 and
subparagraph (f)(2) of Rule 19b–4
thereunder,8 because it establishes a
due, fee, or other charge imposed by
ISE.
At any time within 60 days of the
filing of such proposed rule change, the
Commission summarily may
temporarily suspend 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. If the
Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
should be approved or disapproved.
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:
7 15
8 17
U.S.C. 78s(b)(3)(A)(ii).
CFR 240.19b–4(f)(2).
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Electronic Comments
• Use the Commission’s Internet
comment form https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
No. SR–ISE–2012–94 on the subject
line.
Paper Comments
• Send paper comments in triplicate
to Elizabeth Murphy, Secretary,
Securities and Exchange Commission,
100 F Street NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–ISE–2012–94. This file
number should be included on the
subject line if email 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 Commissions
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. Copies of such filing
also will be available for inspection and
copying at the principal office of the
ISE. 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–2012–94 and should be
submitted by January 3, 2013.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.9
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–30104 Filed 12–12–12; 8:45 am]
BILLING CODE 8011–01–P
9 17
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–68386; File No. SR–FINRA–
2009–060]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Amendment Nos. 1 and 2, and Order
Granting Accelerated Approval of a
Proposed Rule Change, as Modified by
Amendment Nos. 1 and 2, Relating to
FINRA Rule 8210 (Provision of
Information and Testimony and
Inspection and Copying of Books)
December 7, 2012.
I. Introduction
On September 10, 2009, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed a proposed rule change
with the Securities and Exchange
Commission (‘‘SEC’’ or ‘‘Commission’’)
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) 1 and Rule 19b–4
thereunder 2 to amend FINRA Rule 8210
(Provision of Information and
Testimony and Inspection and Copying
of Books). The proposed rule change
was published for comment in the
Federal Register on October 22, 2009.3
The Commission received seven
comment letters on the proposed rule
change.4 On December 22, 2009, FINRA
filed a letter with the Commission
responding to these comments,5 and on
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Exchange Act Release No. 60836 (Oct. 16,
2009), 74 FR 54614 (Oct. 22, 2009) (Notice of Filing
of Proposed Rule Change; File No. SR–FINRA–
2009–060) (‘‘Notice’’).
4 See letters from BTUD, to Elizabeth Murphy,
Secretary, SEC, dated October 29, 2009 (the ‘‘BTUD
Letter’’); Frederick T. Greene, CIMA, Senior V.P.,
Portfolio Manager, Woodforest Financial Services,
Inc., to Elizabeth M. Murphy, Secretary, SEC, dated
October 29, 2009 (the ‘‘Woodforest Letter’’); Neal E.
Nakagiri, President, CEO, CCO, NPB Financial
Group, LLC, to Elizabeth Murphy, Secretary, SEC,
dated October 29, 2009 (the ‘‘NPB Letter’’); Dale E.
Brown, CAE, President & CEO, Financial Services
Institute, Inc., to Elizabeth M. Murphy, Secretary,
SEC, dated November 4, 2009 (the ‘‘FSI Letter’’);
Bari Havlik, Chief Compliance Officer, Charles
Schwab & Co., Inc., to Elizabeth M. Murphy,
Secretary, SEC, dated November 12, 2009 (the
‘‘Schwab Letter’’); Ronald C. Long, Director,
Regulatory Affairs, Wells Fargo Advisors, to
Elizabeth M. Murphy, Secretary, SEC, dated
November 12, 2009 (the ‘‘Wells Fargo Letter’’); and
Ira D. Hammerman, Senior Managing Director and
General Counsel, Securities Industry and Financial
Markets Association, to Elizabeth M. Murphy,
Secretary, SEC, dated December 16, 2009 (the
‘‘SIFMA Letter’’). These letters are available on the
SEC’s Web site at https://www.sec.gov/comments/srfinra-2009–060/finra2009060.shtml.
5 See letter from Stan Macel, Assistant General
Counsel, Regulatory Policy and Oversight, FINRA,
to Elizabeth M. Murphy, Secretary, SEC, dated
2 17
CFR 200.30–3(a)(12).
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Federal Register / Vol. 77, No. 240 / Thursday, December 13, 2012 / Notices
December 21, 2011, FINRA filed
Amendment No. 1 with the Commission
to further respond to the comments and
to propose amendments in response
thereto.6 On December 5, 2012, FINRA
filed Amendment No. 2 with the
Commission to modify a phrase that was
included in Amendment No. 1.7 The
Commission is publishing this notice
and order to solicit comments on
Amendment Nos. 1 and 2 and to
approve the proposed rule change, as
modified by Amendment Nos.1 and 2,
on an accelerated basis.
right to inspect and copy the books,
records, and accounts of all applicable
members and persons with respect to
any matter involved in an investigation,
complaint, examination or proceeding.9
The proposed rule change would clarify
that the information that FINRA staff
shall have the right to inspect and copy
must be in the member’s or person’s
‘‘possession, custody or control.’’ 10 This
language parallels the Federal Rules of
Civil Procedure regarding document
requests and subpoenas for
documents.11
II. Description of the Proposal
FINRA has proposed to amend FINRA
Rule 8210, which confers on FINRA
staff the authority to compel a member,
person associated with a member, or
other person over whom FINRA has
jurisdiction, to produce documents,
provide testimony, or supply written
responses or electronic data in
connection with an investigation,
complaint, examination or adjudicatory
proceeding. The proposed rule change
would clarify the scope of FINRA’s
authority under the rule to inspect and
copy the books, records, and accounts of
such member or person, specify the
method of service for certain
unregistered persons under the rule, and
authorize service on attorneys who are
representing clients.
FINRA Rule 8210 applies to all
members, associated persons, and other
persons over whom FINRA has
jurisdiction, including former associated
persons subject to FINRA’s jurisdiction
as described in the FINRA By-Laws.8
FINRA Rule 8210(c) provides that a
member’s or associated person’s failure
to provide information or testimony or
to permit an inspection and copying of
books, records, or accounts is a violation
of the rule.
Notice to Associated But Unregistered
Persons
FINRA Rule 8210 addresses the legal
concept of service of a written request
by using the term ‘‘notice’’ of a request.
Currently, FINRA Rule 8210(d) states
that, with respect to members and
associated persons, notice shall be
deemed received by the member or
associated person when a copy of the
notice is mailed or otherwise
transmitted to the last known relevant
address of the member or associated
person as reflected in the Central
Registration Depository (‘‘CRD’’). The
CRD system contains information
concerning registered members and
persons,12 but in most instances it does
not contain information concerning
unregistered persons who are or were
associated with a member.13
srobinson on DSK4SPTVN1PROD with
Information in a Member’s or Person’s
Possession, Custody or Control
FINRA Rule 8210(a)(2) currently
provides that FINRA staff shall have the
December 22, 2009 (‘‘Response to Comments’’).
This letter is available on the SEC’s Web site at
https://www.sec.gov/comments/sr-finra-2009–060/
finra2009060.shtml.
6 See Amendment No. 1 dated December 21, 2011
(‘‘Amendment No. 1’’). Amendment No. 1 is
described below in Section III.B., and the text of
Amendment No. 1 is available on FINRA’s Web site
at https://www.finra.org, at the principal office of
FINRA, and on the Commission’s Web site at
https://www.sec.gov/rules/sro.shtml.
7 See Amendment No. 2 dated December 5, 2012
(‘‘Amendment No. 2’’). Amendment No. 2 is
described below in Section III.B., and the text of
Amendment No. 2 is available on FINRA’s Web site
at https://www.finra.org, at the principal office of
FINRA, and on the Commission’s Web site at
https://www.sec.gov/rules/sro.shtml.
8 See FINRA By-Laws, Article V, Section 4(a)
(Retention of Jurisdiction).
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Jkt 229001
9 FINRA Rule 8210(a) provides FINRA
adjudicators with the same rights as FINRA staff to
request information. Although the proposed rule
change would also clarify a FINRA adjudicator’s
authority, no commenters expressed any concerns
that specifically addressed the powers of FINRA
adjudicators.
10 When filing the proposed rule change with the
Commission, FINRA indicated that in using the
word ‘‘control,’’ in addition to possession and
custody, it intended to require members or persons
covered by the rule to provide, for example, records
that they have the legal right, authority, or ability
to obtain upon demand. See Camden Iron & Metal
v. Marubeni Am. Corp., 138 F.R.D. 438, 441 (D.N.J.
1991) (‘‘Federal courts construe ‘control’ very
broadly under [Federal] Rule [of Civil Procedure]
34.’’). Moreover, FINRA indicated that the proposed
addition of ‘‘possession, custody or control’’ to Rule
8210(a)(2) would address questions that have arisen
in litigation regarding the scope of the rule. See,
e.g., In re: Jay Alan Ochanpaugh, Exchange Act
Release No. 54363 (Aug. 25, 2006) (referred to
hereafter as the ‘‘Jay Alan Ochanpaugh’’ decision or
litigation).
11 See Fed. R. Civ. P. 34.
12 Members and registered persons have an
affirmative duty to update CRD with their current
address for at least two years after they have had
their registration terminated. See Notice to Members
99–77 (noting that FINRA requests for information
and disciplinary complaints issued during the
period of FINRA’s retained jurisdiction will be
mailed to a person’s last address in FINRA’s
records).
13 In some limited instances, CRD may contain
information concerning unregistered associated
persons who were required to submit information,
including fingerprint information, to CRD in
connection with their employment.
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Although not routine, some
investigations require FINRA examiners
or investigators to request information
from persons currently or formerly
associated with a member in an
unregistered capacity.14 The current
rule is unclear as to what would
constitute proper notice on such
persons for whom information is not
available in CRD. The proposed rule
change would explicitly address the
methods by which notice would be
deemed received by persons currently
or formerly associated with a member in
an unregistered capacity.
With respect to unregistered persons
currently associated with a member, the
proposed rule change would provide
that notice shall be deemed received by
mailing or otherwise transmitting the
notice to the last known business
address of the member as reflected in
CRD. In addition, the proposed rule
change would retain the provision that
if FINRA staff responsible for
transmitting the notice has actual
knowledge that the member’s address
provided through CRD is out of date or
inaccurate, then a copy of the notice
must be transmitted to both the address
provided through CRD, as well as any
more current address known to FINRA
staff.
With respect to unregistered persons
formerly associated with a member, the
proposed rule change would provide
that notice shall be deemed received
upon personal service, which is defined
as set forth in FINRA Rule 9134(a)(1).15
FINRA Rule 9134(a)(1) is based on
traditional concepts for serving a
summons under Rule 4 of the Federal
Rules of Civil Procedure.
14 Persons associated with a member who are
unregistered may include persons exempt from
registration, e.g., those whose functions are solely
and exclusively clerical or ministerial; those whose
functions are related solely and exclusively to the
member’s need for nominal corporate officers or for
capital participation; and those whose functions are
related solely and exclusively to transactions in
municipal securities, transactions in commodities,
or transactions in security futures (provided they
are registered with a registered futures association).
See, e.g., NASD Rule 1060(a). For purposes of
FINRA Rule 8210, unregistered persons associated
with a member may also include direct owners and
executive officers listed in Schedule A of Form BD
of a member whose job functions do not otherwise
require them to register with FINRA. See FINRA ByLaws, Article I(rr) (definition of ‘‘person associated
with a member’’).
15 FINRA Rule 9134(a)(1) provides as follows:
‘‘Personal service may be accomplished by handing
a copy of the papers to the person required to be
served; leaving a copy at the person’s office with
an employee or other person in charge thereof; or
leaving a copy at the person’s dwelling or usual
place of abode with a person of suitable age and
discretion then residing therein[.]’’
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Federal Register / Vol. 77, No. 240 / Thursday, December 13, 2012 / Notices
Notice to Members and Persons
Represented By Counsel
The proposed rule change would
amend FINRA Rule 8210(d) to explicitly
address issues of service on members or
persons that are known to be
represented by counsel. Currently, the
rule does not explicitly permit FINRA
staff to serve notice on a member’s or
person’s counsel in situations in which
FINRA staff knows that the member or
person is represented by counsel
regarding the matter in question. The
proposed rule change would allow
FINRA staff to recognize that counsel
can act as an authorized agent on behalf
of a member or person. It would provide
that, if FINRA staff knows that a
member or person is represented by
counsel regarding the matter in
question, then notice shall be provided
to counsel rather than to the member or
person. The proposed rule change
would harmonize FINRA’s rule in this
regard with Codes of Professional
Conduct in many states regarding
service on counsel.16
Effective Date
In its filing with the Commission,
FINRA stated that it would announce
the effective date of the proposed rule
change in a Regulatory Notice to be
published no later than 60 days
following Commission approval. The
effective date would be 30 days
following publication of the Regulatory
Notice announcing Commission
approval.
srobinson on DSK4SPTVN1PROD with
III. Summary of Comments, FINRA’s
Response, and Amendment Nos. 1 and
2
As stated above, the Commission
received seven comment letters in
response to the proposed rule change.17
Three commenters supported the
amendments as proposed 18 and four
commenters expressed various concerns
with different aspects of the proposal.19
On December 22, 2009, FINRA filed a
letter with the Commission responding
to these comments,20 and on December
16 See, e.g., American Bar Association model Rule
of Professional Conduct 4.2 (‘‘ABA Rule 4.2’’). ABA
Rule 4.2 provides as follows: ‘‘In representing a
client, a lawyer shall not communicate about the
subject of the representation with a person the
lawyer knows to be represented by another lawyer
in the matter, unless the lawyer has the consent of
the other lawyer or is authorized to do so by law
or a court order.’’ Many states have rules regarding
communication with a person represented by
counsel that are based on ABA Rule 4.2.
17 See supra note 4.
18 See FSI Letter; NPB Letter; and Woodforest
Letter.
19 See BTUD Letter; Schwab Letter; SIFMA Letter;
and Wells Fargo Letter.
20 See Response to Comments, supra note 5.
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Jkt 229001
21, 2011, FINRA filed Amendment No.
1 with the Commission to further
respond to the comments and to
propose amendments in response
thereto.21 On December 5, 2012, FINRA
filed Amendment No. 2 with the
Commission to modify a phrase that was
included in Amendment No. 1.22
A. Summary of, and FINRA’s Responses
to, Comment Letters
1. Information in a Member’s or Person’s
Possession, Custody or Control
Four commenters addressed FINRA’s
proposal to amend FINRA Rule
8210(a)(2).23 FINRA Rule 8210(a)(2)
currently provides that FINRA staff
shall have the right to inspect and copy
the books, records and accounts of all
applicable members and persons ‘‘with
respect to any matter involved in the
investigation, complaint, examination or
proceeding.’’ The proposed rule change
would clarify that the information
subject to FINRA inspection and
copying must be in the member’s or
person’s ‘‘possession, custody or
control.’’
Three commenters expressed concern
that FINRA’s intent to clarify the scope
of its authority regarding requests
pursuant to FINRA Rule 8210
represented an expansion of the current
rule without a meaningful discussion or
consideration of the possible legal and
practical implications and consequences
for member firms, associated persons,
and persons over whom FINRA has
jurisdiction.24 These commenters were
particularly concerned that FINRA
would be able to compel its members
and persons over whom it has
jurisdiction to provide FINRA with
information within the member’s or
person’s ‘‘control.’’ In its filing of the
proposed rule change, FINRA stated that
it intended for the word ‘‘control,’’ in
addition to possession and custody, to
require members or persons covered by
the rule to provide, for example, records
that they have the legal right, authority,
or ability to obtain upon demand.25 In
support of their comments, two
commenters cited to the Commission’s
Jay Alan Ochanpaugh decision, in
which the Commission considered the
authority of the NASD (now FINRA)
under Rule 8210 in a litigation context
and stated that a ‘‘fuller exploration’’ of
the scope of Rule 8210 would be
required by the NASD to support its
21 See
Amendment No. 1, supra note 6.
Amendment No. 2, supra note 7.
23 See BTUD Letter; Schwab Letter; SIFMA Letter;
and Wells Fargo Letter.
24 See Schwab Letter; SIFMA Letter; and Wells
Fargo Letter.
25 See Notice, supra note 3.
22 See
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74255
view in the case that the rule authorized
it to obtain information within a
member’s or person’s possession or
control.26
In its Response to Comments, FINRA
stated that commenters were incorrect
in their analysis of the Jay Alan
Ochanpaugh litigation.27 FINRA noted
that although the Commission’s
decision in that case addressed both the
legal argument that Rule 8210 did not
include the concept of ‘‘possession and
control’’ and the factual argument that
the NASD failed to prove that the
applicant had possession and control of
the documents, the Commission’s
decision to set aside FINRA’s action in
the case was based on factual grounds.28
FINRA also noted that the Exchange
Act, not the decision in Jay Alan
Ochanpaugh, provides the standard the
Commission uses when analyzing a selfregulatory organization’s proposed rule
change.29 FINRA further argued that the
purpose of proposed FINRA Rule 8210
is to facilitate investigations and that the
consequences or burdens of any
particular request are factually specific
to that investigation.30
2. Issues Regarding Access to ThirdParty Documents and Procedural
Protections
Three commenters raised concerns
that the proposed rule change could
permit FINRA to compel members or
associated persons to produce
documents that belong to a third
party.31 For example, two commenters
expressed concern that FINRA would
not be required to maintain
confidentiality of third party documents
it receives pursuant to a Rule 8210
request, which could be made public
when attached to pleadings in court
filings, when sought by another party
pursuant to a subpoena, and when
disclosed pursuant to Freedom of
Information Act requests.32 One of these
commenters expressed further concern
that public disclosure of confidential or
proprietary third party documents as a
result of the proposed rule change may
result in the owner of the documents
suffering material harm, which, in turn,
could prompt the owner of the records
26 See
27 See
Schwab Letter and SIFMA Letter.
Response to Comments, supra note 5.
28 Id.
29 Id. See also Section 19(b)(2)(C) of the Exchange
Act, which states that the Commission shall
approve a proposed rule change of a self-regulatory
organization ‘‘if it finds that such proposed rule
change is consistent with the requirements of this
title and the rules and regulations issued under this
title that are applicable to such organization.’’
30 See Response to Comments, supra note 5.
31 See Schwab Letter; SIFMA Letter; and Wells
Fargo Letter.
32 See Schwab Letter and SIFMA Letter.
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to seek damages or other recourse from
FINRA and the member firm for
publicly disclosing the information.33
To address these concerns, one
commenter recommended that FINRA’s
right to demand possession, custody, or
control of third party records should be
limited to when an associated person is
acting in its capacity as an associated
person.34 This commenter also stated
that FINRA should access documents of
third parties through subpoenas to
provide third parties with a means of
addressing their issues against the
production of their documents and to
help protect member firms against
claims of improper disclosure.35
One commenter stated that FINRA’s
proposal does not address issues
relating to the ownership of records
where FINRA is seeking records of a
third party not within FINRA’s
jurisdiction.36 For example, according
to this commenter, an unrelated third
party may own and have absolute
control over the material requested,
while the person or entity over whom
FINRA has jurisdiction may have
limited access to the documents or only
the right to request the documents from
the third party for a specific purpose
consistent with their role in the
organization or relationship with the
third party.37 The commenter believes
that this may result in the member firm
breaching contractual obligations owed
to the third party and potentially result
in a violation of Rule 8210.38 Another
commenter expressed concern that
under the proposed rule change,
regulators could rely on the subject of
an investigation to supply information
related to third parties as opposed to
independently obtaining those records
from the third party.39
Two commenters expressed concern
about the procedural protections of
which FINRA members may avail
themselves when in receipt of a Rule
8210 request for information.40 These
commenters stated that, although the
rule seeks to adopt the same standard
found in the Federal Rules of Civil
Procedure, FINRA members may not
receive the same procedural protections
as those found in federal court, such as
the right to object to the production of
requested documents.41 These
commenters also stated that if a FINRA
member cannot comply with a request
33 See
srobinson on DSK4SPTVN1PROD with
34 See
Schwab Letter.
Wells Fargo Letter.
42 Id.
43 See
35 Id.
36 See
under Rule 8210, and the firm is found
to have violated the rule, the procedural
process to appeal to the SEC and federal
courts is long and arduous.42
FINRA believes that the concerns
described above relating to issues
regarding access to third party
documents and procedural protections
incorrectly assume that FINRA’s
investigations into the conduct of its
members and associated persons are
strictly limited in scope to the FINRA
members and associated persons under
investigation.43 FINRA stated that
although it has jurisdiction to file an
action against its members and
associated persons (and those otherwise
subject to its jurisdiction), its
investigations can involve non-FINRA
members, including customers, issuers,
or foreign businesses.44 Consequently,
FINRA contends that third party
documents within the ‘‘possession,
custody or control’’ of the FINRA
member or associated person that relate
to the investigation should be produced
pursuant to proposed FINRA Rule 8210
and concerns solely based on their
status as third party documents should
not prevent the Commission from
approving the proposed rule change.45
FINRA agrees in part that its authority
to request documents is contractual.
However, FINRA notes that its authority
is also based on its rules applying to all
members and their associated persons.46
FINRA states that, in light of these
relationships, its investigations are
based on a model of implied
cooperation as opposed to the
adversarial system that is governed by
the Federal Rules of Civil Procedure.47
Specifically, FINRA’s members and
persons subject to its jurisdiction have
already agreed, either explicitly or
implicitly, to supply FINRA with
information during its investigations.48
FINRA notes that once an investigation
has matured into the filing of a
complaint, the FINRA Code of
Procedure affords a respondent several
procedural rights and that its
investigatory process should not be
fundamentally altered as a result of the
proposed rule change.49 FINRA also
notes that the current rule provides
FINRA staff with the right to inspect
and copy books, records, and accounts
of members, associated persons and
others subject to FINRA’s jurisdiction
37 Id.
46 Id.
39 See
40 See
Wells Fargo Letter.
Schwab Letter and SIFMA Letter.
41 Id.
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47 Id.
48 Id.
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4. Additional Analysis and
Consideration of the Proposed Rule
Change
Two commenters recommended that
FINRA engage in additional analysis
and consideration with respect to the
proposed rule change and the process
and protections afforded to members,
associated persons, and others over
whom FINRA has jurisdiction.54 FINRA
did not directly respond to these
recommendations; however, FINRA’s
Response to Comments and its filing of
Amendment Nos. 1 and 2, which, as
discussed below, limit the scope of the
proposed rule change, reflect FINRA’s
efforts to engage in such additional
analysis and consideration of the
proposed rule change.
51 See Schwab Letter; SIFMA Letter; and Wells
Fargo Letter.
52 See Response to Comments, supra note 5.
53 Id.
54 See Schwab Letter and SIFMA Letter.
49 Id.
16:21 Dec 12, 2012
Three commenters indicated that
FINRA Rule 8210(a)(2), as proposed to
be amended, may inhibit or discourage
individuals in the securities industry
from participating in charitable, nonprofit, and board service due to the
potential for third party organizations to
have to provide private or confidential
documents owned by the organization
to FINRA.51 FINRA responded that it
did not find merit in the suggestion by
these commenters that adopting the
‘‘possession, custody or control’’
language in FINRA Rule 8210(a)(2)
would chill the likelihood of associated
persons participating in non-profit
entities due to fear by those entities that
their documents would be disclosed
during FINRA investigations.52 FINRA
stated further that in as much as board
members of non-profit organizations
often are employed in a for-profit
industry, FINRA found no greater
likelihood that a non-profit
corporation’s confidential information
would be disclosed because they have
associated persons as board members
than if their board members were not
associated with the securities
industry.53
50 Id.
45 Id.
38 Id.
3. Participation in Charitable, NonProfit, and Board Service
Response to Comments, supra note 5.
44 Id.
Schwab Letter.
‘‘with respect to any matter involved in
the investigation, complaint,
examination or proceeding,’’ and
because the rule is purposefully
designed to cover a broad range of
activities, concerns about limiting the
scope of the rule are misplaced.50
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5. Notice to Unregistered Persons and
Members and Persons Represented by
Counsel
FINRA did not receive any specific
comments on its proposals under Rule
8210(d) to specify the method of service
for certain unregistered persons and to
authorize service on members or
persons that are known to be
represented by counsel.
6. Comment Outside the Scope of the
Proposed Rule Change
One commenter expressed concern
regarding a witness’s ability to access a
written transcript of on-the-record
testimony in a FINRA proceeding.55
FINRA responded that this comment is
outside the scope of the proposed rule
change.56
B. Description of Amendment Nos. 1
and 2
srobinson on DSK4SPTVN1PROD with
After further consideration and
analysis of the proposed rule change
and the comments thereon, on
December 21, 2011, FINRA filed
Amendment No. 1, in which it proposed
to add Supplementary Material limiting
the scope of its proposal.57 On
December 5, 2012, FINRA filed
Amendment No. 2 to modify a phrase in
the proposed Supplementary Material.58
First, the proposed Supplementary
Material would provide that books,
records and accounts of a broker-dealer,
associated person or person subject to
FINRA’s jurisdiction (as referenced in
Rule 8210(a)), would include those
books, records and accounts that the
broker-dealer or its associated persons
would make or keep relating to its
operation as a broker-dealer or relating
to the person’s association with the
member.59 This would include, but not
be limited to, investigations of outside
business activities, private securities
transactions, or possible violations of
just and equitable principles of trade, as
well as other FINRA rules, MSRB rules,
and the federal securities laws.60
The proposed Supplementary
Material also would clarify that books,
records and accounts of a broker-dealer,
associated person or person subject to
FINRA’s jurisdiction would not
ordinarily include books and records
that are in the possession, custody or
control of a member or associated
person, but whose bona fide ownership
is held by an independent third party
55 See
BTUD Letter.
Response to Comments, supra note 5.
57 See Amendment No. 1, supra note 6.
58 See Amendment No. 2, supra note 7.
59 Id.
60 Id.
56 See
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and the records are unrelated to the
business of the member.61
Finally, the proposed Supplementary
Material would provide that a FINRA
member, associated person, or person
subject to FINRA’s jurisdiction must
make available its books, records or
accounts when these books, records or
accounts are in the possession of
another person or entity, such as an
attorney, accountant, or other
professional service provider, but the
FINRA member, associated person, or
person subject to FINRA’s jurisdiction
controls or has a right to demand
them.62
IV. Discussion and Commission
Findings
The Commission has carefully
considered the proposed rule change, as
modified by Amendment Nos. 1 and 2,
the comment letters received, and
FINRA’s response and finds that the
proposed rule change, as modified by
Amendment Nos. 1 and 2, is consistent
with the requirements of the Exchange
Act and the rules and regulations
thereunder that are applicable to a
national securities association.63 In
particular, the Commission finds that
the proposed rule change, as modified
by Amendment Nos. 1 and 2, is
consistent with Section 15A(b)(6) of the
Exchange Act, which requires, among
other things, that the rules of a national
securities association be designed to
prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, remove
impediments to and perfect the
mechanism of a free and open market
and a national market system, and, in
general, protect investors and the public
interest.64 The Commission believes
that FINRA, in its Response to
Comments and Amendment Nos. 1 and
2, adequately addressed the comments
raised in response to the Notice.
Current FINRA Rule 8210 confers on
FINRA staff authority to compel a
member, person associated with a
61 Id.
62 Id. Amendment No. 1 also makes a technical
change to the text of Rule 8210 to reflect the
addition of paragraph (g) to the Rule, which was
added through a separate and unrelated intervening
proposed rule change that was submitted and
became effective subsequent to the filing of this
proposal. See Exchange Act Release No. 63016 (Sep.
29, 2010), 75 FR 61793 (Oct. 6, 2010) (Order
Approving Proposed Rule Change; File No. SR–
FINRA–2010–021). This change has no effect on the
text of Rule 8210(g), which requires the encryption
of certain information provided via portable media
device. Id.
63 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).
64 15 U.S.C. 78o–3(b)(6).
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Sfmt 4703
74257
member, or other person subject to
FINRA’s jurisdiction, to produce
documents, provide testimony, or
supply written responses or electronic
data in connection with an
investigation, complaint, examination or
adjudicatory proceeding. Additionally,
the current rule provides FINRA with
the authority to inspect and copy the
books, records, and accounts of all
applicable members and persons with
respect to any matter involved in the
investigation, complaint, examination,
or proceeding. FINRA’s proposed rule,
as modified by Amendment Nos. 1 and
2, clarifies that information subject to a
FINRA Rule 8210 request must be in the
member’s or person’s ‘‘possession,
custody or control’’ and explicitly
provides the methods by which certain
types of notice must be made. These
changes will help eliminate existing
confusion with respect to the scope of
FINRA Rule 8210. The proposed rule
change, as modified by Amendment
Nos. 1 and 2, also will further the
purposes of the Exchange Act by, among
other things, clarifying and streamlining
the requirements surrounding providing
information and testimony and
inspecting and copying books and
records. The clarifying nature of the
proposed rule, as modified by
Amendment Nos. 1 and 2, will be
helpful to FINRA members in
understanding the scope of, and notice
requirements under, Rule 8210, and will
assist FINRA in facilitating
investigations and fulfilling its
responsibilities as a self-regulatory
organization under the Exchange Act.
V. Accelerated Approval
The Commission finds goods cause,
pursuant to Section 19(b)(2) of the
Act,65 for approving the proposed rule
change, as modified by Amendment
Nos. 1 and 2, prior to the 30th day after
publication of Amendment Nos. 1 and
2 in the Federal Register. The changes
proposed in Amendment Nos. 1 and 2
respond to specific concerns raised by
commenters and do not raise novel
regulatory concerns. In particular,
Amendment Nos. 1 and 2 clarify the
scope of FINRA Rule 8210 and FINRA’s
authority to inspect and copy the books,
records and accounts of members and
persons with respect to any matter
involved in an investigation, complaint,
examination, or proceeding. The
proposed rule, as modified by
Amendment Nos. 1 and 2, also furthers
FINRA’s investor protection mandate.
Accordingly, the Commission finds
that good cause exists to approve the
65 15
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Federal Register / Vol. 77, No. 240 / Thursday, December 13, 2012 / Notices
proposal, as modified by Amendment
Nos. 1 and 2, on an accelerated basis.
VI. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether Amendment Nos. 1
and 2 to the proposed rule change are
consistent with the Exchange Act.
Comments may be submitted by any of
the following methods:
VII. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,66 that the
proposed rule change (SR–FINRA–
2009–060), as modified by Amendment
Nos. 1 and 2, be, and hereby is,
approved on an accelerated basis.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.67
Kevin M. O’Neill,
Deputy Secretary.
Electronic Comments
[FR Doc. 2012–30049 Filed 12–12–12; 8:45 am]
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–FINRA–2009–060 on the
subject line.
BILLING CODE 8011–01–P
Paper Comments
Self-Regulatory Organizations; NYSE
MKT LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Amending Exchange
Rule 952NY With Respect to Opening
Trading in an Options Series
srobinson on DSK4SPTVN1PROD with
• 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–2009–060. This file
number should be included on the
subject line if email 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–2009–060 and
should be submitted on or before
January 3, 2013.
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–68383; File No. SR–
NYSEMKT–2012–72]
December 7, 2012.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that, on
November 26, 2012, NYSE MKT LLC
(the ‘‘Exchange’’ or ‘‘NYSE MKT’’) filed
with the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. 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
The Exchange proposes to amend
Exchange Rule 952NY (Trading
Auctions) with respect to opening
trading in an options series. The text of
the proposed rule change is available on
the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, 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
66 15
U.S.C. 78(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
67 17
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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 those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Rule 952NY to provide for how the
System 3 may open an options series for
trading when there are no executable
orders and/or quotes and the bid-ask
differential of the NBBO disseminated
by Options Price Reporting Authority
(‘‘OPRA’’) or a Market Maker quote does
not exceed the bid-ask differential
specified under Rule 925NY(b)(4). The
Exchange’s Rules are currently silent on
how the System opens an options series
when it does not conduct an auction.
Specifically, the proposed rule change
(i) will codify that the Exchange opens
an option series when there are no
executable orders and/or quotes to
match up in the System (‘‘open a series
on a quote’’), which is currently based
on the bid-ask differentials that are
within the acceptable range defined in
Rule 925NY(b)(4); and (ii) will also
amend the current process to provide
that the bid-ask differential to allow for
the System to open a series on a quote
would be based on the bid-ask
differentials specified in Rule
925NY(b)(5), which are wider than the
bid-ask differential that allows for the
System to open via an auction during
the Auction Process.
Current Opening Process
Currently, Rule 952NY describes the
process pursuant to which the System
opens an option series. Pursuant to the
procedures described in Rule 952NY(b)
and (c), after the primary market for the
underlying security disseminates the
opening trade or opening quote, the
System conducts an ‘‘Auction Process’’
to open a series whereby the System
determines a single price at which a
series may be opened by looking either
to: (i) the midpoint of the initial
uncrossed NBBO disseminated by the
Options Price Reporting Authority
3 The term ‘‘System’’ refers to the Exchange’s
electronic order delivery, execution and reporting
system through which orders and quotes for listed
options are consolidated for execution and/or
display.
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Agencies
[Federal Register Volume 77, Number 240 (Thursday, December 13, 2012)]
[Notices]
[Pages 74253-74258]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-30049]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-68386; File No. SR-FINRA-2009-060]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of Amendment Nos. 1 and 2, and Order
Granting Accelerated Approval of a Proposed Rule Change, as Modified by
Amendment Nos. 1 and 2, Relating to FINRA Rule 8210 (Provision of
Information and Testimony and Inspection and Copying of Books)
December 7, 2012.
I. Introduction
On September 10, 2009, the Financial Industry Regulatory Authority,
Inc. (``FINRA'') filed a proposed rule change with the Securities and
Exchange Commission (``SEC'' or ``Commission'') pursuant to Section
19(b)(1) of the Securities Exchange Act of 1934 (``Exchange Act'') \1\
and Rule 19b-4 thereunder \2\ to amend FINRA Rule 8210 (Provision of
Information and Testimony and Inspection and Copying of Books). The
proposed rule change was published for comment in the Federal Register
on October 22, 2009.\3\ The Commission received seven comment letters
on the proposed rule change.\4\ On December 22, 2009, FINRA filed a
letter with the Commission responding to these comments,\5\ and on
[[Page 74254]]
December 21, 2011, FINRA filed Amendment No. 1 with the Commission to
further respond to the comments and to propose amendments in response
thereto.\6\ On December 5, 2012, FINRA filed Amendment No. 2 with the
Commission to modify a phrase that was included in Amendment No. 1.\7\
The Commission is publishing this notice and order to solicit comments
on Amendment Nos. 1 and 2 and to approve the proposed rule change, as
modified by Amendment Nos.1 and 2, on an accelerated basis.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Exchange Act Release No. 60836 (Oct. 16, 2009), 74 FR
54614 (Oct. 22, 2009) (Notice of Filing of Proposed Rule Change;
File No. SR-FINRA-2009-060) (``Notice'').
\4\ See letters from BTUD, to Elizabeth Murphy, Secretary, SEC,
dated October 29, 2009 (the ``BTUD Letter''); Frederick T. Greene,
CIMA, Senior V.P., Portfolio Manager, Woodforest Financial Services,
Inc., to Elizabeth M. Murphy, Secretary, SEC, dated October 29, 2009
(the ``Woodforest Letter''); Neal E. Nakagiri, President, CEO, CCO,
NPB Financial Group, LLC, to Elizabeth Murphy, Secretary, SEC, dated
October 29, 2009 (the ``NPB Letter''); Dale E. Brown, CAE, President
& CEO, Financial Services Institute, Inc., to Elizabeth M. Murphy,
Secretary, SEC, dated November 4, 2009 (the ``FSI Letter''); Bari
Havlik, Chief Compliance Officer, Charles Schwab & Co., Inc., to
Elizabeth M. Murphy, Secretary, SEC, dated November 12, 2009 (the
``Schwab Letter''); Ronald C. Long, Director, Regulatory Affairs,
Wells Fargo Advisors, to Elizabeth M. Murphy, Secretary, SEC, dated
November 12, 2009 (the ``Wells Fargo Letter''); and Ira D.
Hammerman, Senior Managing Director and General Counsel, Securities
Industry and Financial Markets Association, to Elizabeth M. Murphy,
Secretary, SEC, dated December 16, 2009 (the ``SIFMA Letter'').
These letters are available on the SEC's Web site at https://www.sec.gov/comments/sr-finra-2009-060/finra2009060.shtml.
\5\ See letter from Stan Macel, Assistant General Counsel,
Regulatory Policy and Oversight, FINRA, to Elizabeth M. Murphy,
Secretary, SEC, dated December 22, 2009 (``Response to Comments'').
This letter is available on the SEC's Web site at https://www.sec.gov/comments/sr-finra-2009-060/finra2009060.shtml.
\6\ See Amendment No. 1 dated December 21, 2011 (``Amendment No.
1''). Amendment No. 1 is described below in Section III.B., and the
text of Amendment No. 1 is available on FINRA's Web site at https://www.finra.org, at the principal office of FINRA, and on the
Commission's Web site at https://www.sec.gov/rules/sro.shtml.
\7\ See Amendment No. 2 dated December 5, 2012 (``Amendment No.
2''). Amendment No. 2 is described below in Section III.B., and the
text of Amendment No. 2 is available on FINRA's Web site at https://www.finra.org, at the principal office of FINRA, and on the
Commission's Web site at https://www.sec.gov/rules/sro.shtml.
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II. Description of the Proposal
FINRA has proposed to amend FINRA Rule 8210, which confers on FINRA
staff the authority to compel a member, person associated with a
member, or other person over whom FINRA has jurisdiction, to produce
documents, provide testimony, or supply written responses or electronic
data in connection with an investigation, complaint, examination or
adjudicatory proceeding. The proposed rule change would clarify the
scope of FINRA's authority under the rule to inspect and copy the
books, records, and accounts of such member or person, specify the
method of service for certain unregistered persons under the rule, and
authorize service on attorneys who are representing clients.
FINRA Rule 8210 applies to all members, associated persons, and
other persons over whom FINRA has jurisdiction, including former
associated persons subject to FINRA's jurisdiction as described in the
FINRA By-Laws.\8\ FINRA Rule 8210(c) provides that a member's or
associated person's failure to provide information or testimony or to
permit an inspection and copying of books, records, or accounts is a
violation of the rule.
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\8\ See FINRA By-Laws, Article V, Section 4(a) (Retention of
Jurisdiction).
---------------------------------------------------------------------------
Information in a Member's or Person's Possession, Custody or Control
FINRA Rule 8210(a)(2) currently provides that FINRA staff shall
have the right to inspect and copy the books, records, and accounts of
all applicable members and persons with respect to any matter involved
in an investigation, complaint, examination or proceeding.\9\ The
proposed rule change would clarify that the information that FINRA
staff shall have the right to inspect and copy must be in the member's
or person's ``possession, custody or control.'' \10\ This language
parallels the Federal Rules of Civil Procedure regarding document
requests and subpoenas for documents.\11\
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\9\ FINRA Rule 8210(a) provides FINRA adjudicators with the same
rights as FINRA staff to request information. Although the proposed
rule change would also clarify a FINRA adjudicator's authority, no
commenters expressed any concerns that specifically addressed the
powers of FINRA adjudicators.
\10\ When filing the proposed rule change with the Commission,
FINRA indicated that in using the word ``control,'' in addition to
possession and custody, it intended to require members or persons
covered by the rule to provide, for example, records that they have
the legal right, authority, or ability to obtain upon demand. See
Camden Iron & Metal v. Marubeni Am. Corp., 138 F.R.D. 438, 441
(D.N.J. 1991) (``Federal courts construe `control' very broadly
under [Federal] Rule [of Civil Procedure] 34.''). Moreover, FINRA
indicated that the proposed addition of ``possession, custody or
control'' to Rule 8210(a)(2) would address questions that have
arisen in litigation regarding the scope of the rule. See, e.g., In
re: Jay Alan Ochanpaugh, Exchange Act Release No. 54363 (Aug. 25,
2006) (referred to hereafter as the ``Jay Alan Ochanpaugh'' decision
or litigation).
\11\ See Fed. R. Civ. P. 34.
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Notice to Associated But Unregistered Persons
FINRA Rule 8210 addresses the legal concept of service of a written
request by using the term ``notice'' of a request. Currently, FINRA
Rule 8210(d) states that, with respect to members and associated
persons, notice shall be deemed received by the member or associated
person when a copy of the notice is mailed or otherwise transmitted to
the last known relevant address of the member or associated person as
reflected in the Central Registration Depository (``CRD''). The CRD
system contains information concerning registered members and
persons,\12\ but in most instances it does not contain information
concerning unregistered persons who are or were associated with a
member.\13\
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\12\ Members and registered persons have an affirmative duty to
update CRD with their current address for at least two years after
they have had their registration terminated. See Notice to Members
99-77 (noting that FINRA requests for information and disciplinary
complaints issued during the period of FINRA's retained jurisdiction
will be mailed to a person's last address in FINRA's records).
\13\ In some limited instances, CRD may contain information
concerning unregistered associated persons who were required to
submit information, including fingerprint information, to CRD in
connection with their employment.
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Although not routine, some investigations require FINRA examiners
or investigators to request information from persons currently or
formerly associated with a member in an unregistered capacity.\14\ The
current rule is unclear as to what would constitute proper notice on
such persons for whom information is not available in CRD. The proposed
rule change would explicitly address the methods by which notice would
be deemed received by persons currently or formerly associated with a
member in an unregistered capacity.
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\14\ Persons associated with a member who are unregistered may
include persons exempt from registration, e.g., those whose
functions are solely and exclusively clerical or ministerial; those
whose functions are related solely and exclusively to the member's
need for nominal corporate officers or for capital participation;
and those whose functions are related solely and exclusively to
transactions in municipal securities, transactions in commodities,
or transactions in security futures (provided they are registered
with a registered futures association). See, e.g., NASD Rule
1060(a). For purposes of FINRA Rule 8210, unregistered persons
associated with a member may also include direct owners and
executive officers listed in Schedule A of Form BD of a member whose
job functions do not otherwise require them to register with FINRA.
See FINRA By-Laws, Article I(rr) (definition of ``person associated
with a member'').
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With respect to unregistered persons currently associated with a
member, the proposed rule change would provide that notice shall be
deemed received by mailing or otherwise transmitting the notice to the
last known business address of the member as reflected in CRD. In
addition, the proposed rule change would retain the provision that if
FINRA staff responsible for transmitting the notice has actual
knowledge that the member's address provided through CRD is out of date
or inaccurate, then a copy of the notice must be transmitted to both
the address provided through CRD, as well as any more current address
known to FINRA staff.
With respect to unregistered persons formerly associated with a
member, the proposed rule change would provide that notice shall be
deemed received upon personal service, which is defined as set forth in
FINRA Rule 9134(a)(1).\15\ FINRA Rule 9134(a)(1) is based on
traditional concepts for serving a summons under Rule 4 of the Federal
Rules of Civil Procedure.
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\15\ FINRA Rule 9134(a)(1) provides as follows: ``Personal
service may be accomplished by handing a copy of the papers to the
person required to be served; leaving a copy at the person's office
with an employee or other person in charge thereof; or leaving a
copy at the person's dwelling or usual place of abode with a person
of suitable age and discretion then residing therein[.]''
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[[Page 74255]]
Notice to Members and Persons Represented By Counsel
The proposed rule change would amend FINRA Rule 8210(d) to
explicitly address issues of service on members or persons that are
known to be represented by counsel. Currently, the rule does not
explicitly permit FINRA staff to serve notice on a member's or person's
counsel in situations in which FINRA staff knows that the member or
person is represented by counsel regarding the matter in question. The
proposed rule change would allow FINRA staff to recognize that counsel
can act as an authorized agent on behalf of a member or person. It
would provide that, if FINRA staff knows that a member or person is
represented by counsel regarding the matter in question, then notice
shall be provided to counsel rather than to the member or person. The
proposed rule change would harmonize FINRA's rule in this regard with
Codes of Professional Conduct in many states regarding service on
counsel.\16\
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\16\ See, e.g., American Bar Association model Rule of
Professional Conduct 4.2 (``ABA Rule 4.2''). ABA Rule 4.2 provides
as follows: ``In representing a client, a lawyer shall not
communicate about the subject of the representation with a person
the lawyer knows to be represented by another lawyer in the matter,
unless the lawyer has the consent of the other lawyer or is
authorized to do so by law or a court order.'' Many states have
rules regarding communication with a person represented by counsel
that are based on ABA Rule 4.2.
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Effective Date
In its filing with the Commission, FINRA stated that it would
announce the effective date of the proposed rule change in a Regulatory
Notice to be published no later than 60 days following Commission
approval. The effective date would be 30 days following publication of
the Regulatory Notice announcing Commission approval.
III. Summary of Comments, FINRA's Response, and Amendment Nos. 1 and 2
As stated above, the Commission received seven comment letters in
response to the proposed rule change.\17\ Three commenters supported
the amendments as proposed \18\ and four commenters expressed various
concerns with different aspects of the proposal.\19\ On December 22,
2009, FINRA filed a letter with the Commission responding to these
comments,\20\ and on December 21, 2011, FINRA filed Amendment No. 1
with the Commission to further respond to the comments and to propose
amendments in response thereto.\21\ On December 5, 2012, FINRA filed
Amendment No. 2 with the Commission to modify a phrase that was
included in Amendment No. 1.\22\
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\17\ See supra note 4.
\18\ See FSI Letter; NPB Letter; and Woodforest Letter.
\19\ See BTUD Letter; Schwab Letter; SIFMA Letter; and Wells
Fargo Letter.
\20\ See Response to Comments, supra note 5.
\21\ See Amendment No. 1, supra note 6.
\22\ See Amendment No. 2, supra note 7.
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A. Summary of, and FINRA's Responses to, Comment Letters
1. Information in a Member's or Person's Possession, Custody or Control
Four commenters addressed FINRA's proposal to amend FINRA Rule
8210(a)(2).\23\ FINRA Rule 8210(a)(2) currently provides that FINRA
staff shall have the right to inspect and copy the books, records and
accounts of all applicable members and persons ``with respect to any
matter involved in the investigation, complaint, examination or
proceeding.'' The proposed rule change would clarify that the
information subject to FINRA inspection and copying must be in the
member's or person's ``possession, custody or control.''
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\23\ See BTUD Letter; Schwab Letter; SIFMA Letter; and Wells
Fargo Letter.
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Three commenters expressed concern that FINRA's intent to clarify
the scope of its authority regarding requests pursuant to FINRA Rule
8210 represented an expansion of the current rule without a meaningful
discussion or consideration of the possible legal and practical
implications and consequences for member firms, associated persons, and
persons over whom FINRA has jurisdiction.\24\ These commenters were
particularly concerned that FINRA would be able to compel its members
and persons over whom it has jurisdiction to provide FINRA with
information within the member's or person's ``control.'' In its filing
of the proposed rule change, FINRA stated that it intended for the word
``control,'' in addition to possession and custody, to require members
or persons covered by the rule to provide, for example, records that
they have the legal right, authority, or ability to obtain upon
demand.\25\ In support of their comments, two commenters cited to the
Commission's Jay Alan Ochanpaugh decision, in which the Commission
considered the authority of the NASD (now FINRA) under Rule 8210 in a
litigation context and stated that a ``fuller exploration'' of the
scope of Rule 8210 would be required by the NASD to support its view in
the case that the rule authorized it to obtain information within a
member's or person's possession or control.\26\
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\24\ See Schwab Letter; SIFMA Letter; and Wells Fargo Letter.
\25\ See Notice, supra note 3.
\26\ See Schwab Letter and SIFMA Letter.
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In its Response to Comments, FINRA stated that commenters were
incorrect in their analysis of the Jay Alan Ochanpaugh litigation.\27\
FINRA noted that although the Commission's decision in that case
addressed both the legal argument that Rule 8210 did not include the
concept of ``possession and control'' and the factual argument that the
NASD failed to prove that the applicant had possession and control of
the documents, the Commission's decision to set aside FINRA's action in
the case was based on factual grounds.\28\ FINRA also noted that the
Exchange Act, not the decision in Jay Alan Ochanpaugh, provides the
standard the Commission uses when analyzing a self-regulatory
organization's proposed rule change.\29\ FINRA further argued that the
purpose of proposed FINRA Rule 8210 is to facilitate investigations and
that the consequences or burdens of any particular request are
factually specific to that investigation.\30\
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\27\ See Response to Comments, supra note 5.
\28\ Id.
\29\ Id. See also Section 19(b)(2)(C) of the Exchange Act, which
states that the Commission shall approve a proposed rule change of a
self-regulatory organization ``if it finds that such proposed rule
change is consistent with the requirements of this title and the
rules and regulations issued under this title that are applicable to
such organization.''
\30\ See Response to Comments, supra note 5.
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2. Issues Regarding Access to Third-Party Documents and Procedural
Protections
Three commenters raised concerns that the proposed rule change
could permit FINRA to compel members or associated persons to produce
documents that belong to a third party.\31\ For example, two commenters
expressed concern that FINRA would not be required to maintain
confidentiality of third party documents it receives pursuant to a Rule
8210 request, which could be made public when attached to pleadings in
court filings, when sought by another party pursuant to a subpoena, and
when disclosed pursuant to Freedom of Information Act requests.\32\ One
of these commenters expressed further concern that public disclosure of
confidential or proprietary third party documents as a result of the
proposed rule change may result in the owner of the documents suffering
material harm, which, in turn, could prompt the owner of the records
[[Page 74256]]
to seek damages or other recourse from FINRA and the member firm for
publicly disclosing the information.\33\
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\31\ See Schwab Letter; SIFMA Letter; and Wells Fargo Letter.
\32\ See Schwab Letter and SIFMA Letter.
\33\ See Schwab Letter.
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To address these concerns, one commenter recommended that FINRA's
right to demand possession, custody, or control of third party records
should be limited to when an associated person is acting in its
capacity as an associated person.\34\ This commenter also stated that
FINRA should access documents of third parties through subpoenas to
provide third parties with a means of addressing their issues against
the production of their documents and to help protect member firms
against claims of improper disclosure.\35\
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\34\ See Wells Fargo Letter.
\35\ Id.
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One commenter stated that FINRA's proposal does not address issues
relating to the ownership of records where FINRA is seeking records of
a third party not within FINRA's jurisdiction.\36\ For example,
according to this commenter, an unrelated third party may own and have
absolute control over the material requested, while the person or
entity over whom FINRA has jurisdiction may have limited access to the
documents or only the right to request the documents from the third
party for a specific purpose consistent with their role in the
organization or relationship with the third party.\37\ The commenter
believes that this may result in the member firm breaching contractual
obligations owed to the third party and potentially result in a
violation of Rule 8210.\38\ Another commenter expressed concern that
under the proposed rule change, regulators could rely on the subject of
an investigation to supply information related to third parties as
opposed to independently obtaining those records from the third
party.\39\
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\36\ See Schwab Letter.
\37\ Id.
\38\ Id.
\39\ See Wells Fargo Letter.
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Two commenters expressed concern about the procedural protections
of which FINRA members may avail themselves when in receipt of a Rule
8210 request for information.\40\ These commenters stated that,
although the rule seeks to adopt the same standard found in the Federal
Rules of Civil Procedure, FINRA members may not receive the same
procedural protections as those found in federal court, such as the
right to object to the production of requested documents.\41\ These
commenters also stated that if a FINRA member cannot comply with a
request under Rule 8210, and the firm is found to have violated the
rule, the procedural process to appeal to the SEC and federal courts is
long and arduous.\42\
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\40\ See Schwab Letter and SIFMA Letter.
\41\ Id.
\42\ Id.
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FINRA believes that the concerns described above relating to issues
regarding access to third party documents and procedural protections
incorrectly assume that FINRA's investigations into the conduct of its
members and associated persons are strictly limited in scope to the
FINRA members and associated persons under investigation.\43\ FINRA
stated that although it has jurisdiction to file an action against its
members and associated persons (and those otherwise subject to its
jurisdiction), its investigations can involve non-FINRA members,
including customers, issuers, or foreign businesses.\44\ Consequently,
FINRA contends that third party documents within the ``possession,
custody or control'' of the FINRA member or associated person that
relate to the investigation should be produced pursuant to proposed
FINRA Rule 8210 and concerns solely based on their status as third
party documents should not prevent the Commission from approving the
proposed rule change.\45\
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\43\ See Response to Comments, supra note 5.
\44\ Id.
\45\ Id.
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FINRA agrees in part that its authority to request documents is
contractual. However, FINRA notes that its authority is also based on
its rules applying to all members and their associated persons.\46\
FINRA states that, in light of these relationships, its investigations
are based on a model of implied cooperation as opposed to the
adversarial system that is governed by the Federal Rules of Civil
Procedure.\47\ Specifically, FINRA's members and persons subject to its
jurisdiction have already agreed, either explicitly or implicitly, to
supply FINRA with information during its investigations.\48\ FINRA
notes that once an investigation has matured into the filing of a
complaint, the FINRA Code of Procedure affords a respondent several
procedural rights and that its investigatory process should not be
fundamentally altered as a result of the proposed rule change.\49\
FINRA also notes that the current rule provides FINRA staff with the
right to inspect and copy books, records, and accounts of members,
associated persons and others subject to FINRA's jurisdiction ``with
respect to any matter involved in the investigation, complaint,
examination or proceeding,'' and because the rule is purposefully
designed to cover a broad range of activities, concerns about limiting
the scope of the rule are misplaced.\50\
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\46\ Id.
\47\ Id.
\48\ Id.
\49\ Id.
\50\ Id.
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3. Participation in Charitable, Non-Profit, and Board Service
Three commenters indicated that FINRA Rule 8210(a)(2), as proposed
to be amended, may inhibit or discourage individuals in the securities
industry from participating in charitable, non-profit, and board
service due to the potential for third party organizations to have to
provide private or confidential documents owned by the organization to
FINRA.\51\ FINRA responded that it did not find merit in the suggestion
by these commenters that adopting the ``possession, custody or
control'' language in FINRA Rule 8210(a)(2) would chill the likelihood
of associated persons participating in non-profit entities due to fear
by those entities that their documents would be disclosed during FINRA
investigations.\52\ FINRA stated further that in as much as board
members of non-profit organizations often are employed in a for-profit
industry, FINRA found no greater likelihood that a non-profit
corporation's confidential information would be disclosed because they
have associated persons as board members than if their board members
were not associated with the securities industry.\53\
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\51\ See Schwab Letter; SIFMA Letter; and Wells Fargo Letter.
\52\ See Response to Comments, supra note 5.
\53\ Id.
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4. Additional Analysis and Consideration of the Proposed Rule Change
Two commenters recommended that FINRA engage in additional analysis
and consideration with respect to the proposed rule change and the
process and protections afforded to members, associated persons, and
others over whom FINRA has jurisdiction.\54\ FINRA did not directly
respond to these recommendations; however, FINRA's Response to Comments
and its filing of Amendment Nos. 1 and 2, which, as discussed below,
limit the scope of the proposed rule change, reflect FINRA's efforts to
engage in such additional analysis and consideration of the proposed
rule change.
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\54\ See Schwab Letter and SIFMA Letter.
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[[Page 74257]]
5. Notice to Unregistered Persons and Members and Persons Represented
by Counsel
FINRA did not receive any specific comments on its proposals under
Rule 8210(d) to specify the method of service for certain unregistered
persons and to authorize service on members or persons that are known
to be represented by counsel.
6. Comment Outside the Scope of the Proposed Rule Change
One commenter expressed concern regarding a witness's ability to
access a written transcript of on-the-record testimony in a FINRA
proceeding.\55\ FINRA responded that this comment is outside the scope
of the proposed rule change.\56\
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\55\ See BTUD Letter.
\56\ See Response to Comments, supra note 5.
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B. Description of Amendment Nos. 1 and 2
After further consideration and analysis of the proposed rule
change and the comments thereon, on December 21, 2011, FINRA filed
Amendment No. 1, in which it proposed to add Supplementary Material
limiting the scope of its proposal.\57\ On December 5, 2012, FINRA
filed Amendment No. 2 to modify a phrase in the proposed Supplementary
Material.\58\
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\57\ See Amendment No. 1, supra note 6.
\58\ See Amendment No. 2, supra note 7.
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First, the proposed Supplementary Material would provide that
books, records and accounts of a broker-dealer, associated person or
person subject to FINRA's jurisdiction (as referenced in Rule 8210(a)),
would include those books, records and accounts that the broker-dealer
or its associated persons would make or keep relating to its operation
as a broker-dealer or relating to the person's association with the
member.\59\ This would include, but not be limited to, investigations
of outside business activities, private securities transactions, or
possible violations of just and equitable principles of trade, as well
as other FINRA rules, MSRB rules, and the federal securities laws.\60\
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\59\ Id.
\60\ Id.
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The proposed Supplementary Material also would clarify that books,
records and accounts of a broker-dealer, associated person or person
subject to FINRA's jurisdiction would not ordinarily include books and
records that are in the possession, custody or control of a member or
associated person, but whose bona fide ownership is held by an
independent third party and the records are unrelated to the business
of the member.\61\
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\61\ Id.
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Finally, the proposed Supplementary Material would provide that a
FINRA member, associated person, or person subject to FINRA's
jurisdiction must make available its books, records or accounts when
these books, records or accounts are in the possession of another
person or entity, such as an attorney, accountant, or other
professional service provider, but the FINRA member, associated person,
or person subject to FINRA's jurisdiction controls or has a right to
demand them.\62\
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\62\ Id. Amendment No. 1 also makes a technical change to the
text of Rule 8210 to reflect the addition of paragraph (g) to the
Rule, which was added through a separate and unrelated intervening
proposed rule change that was submitted and became effective
subsequent to the filing of this proposal. See Exchange Act Release
No. 63016 (Sep. 29, 2010), 75 FR 61793 (Oct. 6, 2010) (Order
Approving Proposed Rule Change; File No. SR-FINRA-2010-021). This
change has no effect on the text of Rule 8210(g), which requires the
encryption of certain information provided via portable media
device. Id.
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IV. Discussion and Commission Findings
The Commission has carefully considered the proposed rule change,
as modified by Amendment Nos. 1 and 2, the comment letters received,
and FINRA's response and finds that the proposed rule change, as
modified by Amendment Nos. 1 and 2, is consistent with the requirements
of the Exchange Act and the rules and regulations thereunder that are
applicable to a national securities association.\63\ In particular, the
Commission finds that the proposed rule change, as modified by
Amendment Nos. 1 and 2, is consistent with Section 15A(b)(6) of the
Exchange Act, which requires, among other things, that the rules of a
national securities association be designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, remove impediments to and perfect the mechanism of
a free and open market and a national market system, and, in general,
protect investors and the public interest.\64\ The Commission believes
that FINRA, in its Response to Comments and Amendment Nos. 1 and 2,
adequately addressed the comments raised in response to the Notice.
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\63\ 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).
\64\ 15 U.S.C. 78o-3(b)(6).
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Current FINRA Rule 8210 confers on FINRA staff authority to compel
a member, person associated with a member, or other person subject to
FINRA's jurisdiction, to produce documents, provide testimony, or
supply written responses or electronic data in connection with an
investigation, complaint, examination or adjudicatory proceeding.
Additionally, the current rule provides FINRA with the authority to
inspect and copy the books, records, and accounts of all applicable
members and persons with respect to any matter involved in the
investigation, complaint, examination, or proceeding. FINRA's proposed
rule, as modified by Amendment Nos. 1 and 2, clarifies that information
subject to a FINRA Rule 8210 request must be in the member's or
person's ``possession, custody or control'' and explicitly provides the
methods by which certain types of notice must be made. These changes
will help eliminate existing confusion with respect to the scope of
FINRA Rule 8210. The proposed rule change, as modified by Amendment
Nos. 1 and 2, also will further the purposes of the Exchange Act by,
among other things, clarifying and streamlining the requirements
surrounding providing information and testimony and inspecting and
copying books and records. The clarifying nature of the proposed rule,
as modified by Amendment Nos. 1 and 2, will be helpful to FINRA members
in understanding the scope of, and notice requirements under, Rule
8210, and will assist FINRA in facilitating investigations and
fulfilling its responsibilities as a self-regulatory organization under
the Exchange Act.
V. Accelerated Approval
The Commission finds goods cause, pursuant to Section 19(b)(2) of
the Act,\65\ for approving the proposed rule change, as modified by
Amendment Nos. 1 and 2, prior to the 30th day after publication of
Amendment Nos. 1 and 2 in the Federal Register. The changes proposed in
Amendment Nos. 1 and 2 respond to specific concerns raised by
commenters and do not raise novel regulatory concerns. In particular,
Amendment Nos. 1 and 2 clarify the scope of FINRA Rule 8210 and FINRA's
authority to inspect and copy the books, records and accounts of
members and persons with respect to any matter involved in an
investigation, complaint, examination, or proceeding. The proposed
rule, as modified by Amendment Nos. 1 and 2, also furthers FINRA's
investor protection mandate.
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\65\ 15 U.S.C. 78s(b)(2).
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Accordingly, the Commission finds that good cause exists to approve
the
[[Page 74258]]
proposal, as modified by Amendment Nos. 1 and 2, on an accelerated
basis.
VI. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether Amendment Nos. 1
and 2 to the proposed rule change are consistent with the Exchange 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 email to rule-comments@sec.gov. Please include
File Number SR-FINRA-2009-060 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-2009-060. This
file number should be included on the subject line if email 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-2009-060 and should be
submitted on or before January 3, 2013.
VII. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\66\ that the proposed rule change (SR-FINRA-2009-060), as modified
by Amendment Nos. 1 and 2, be, and hereby is, approved on an
accelerated basis.
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\66\ 15 U.S.C. 78(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\67\
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\67\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-30049 Filed 12-12-12; 8:45 am]
BILLING CODE 8011-01-P