Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving a Proposed Rule Change To Amend FINRA Rule 2210 (Communications With the Public), 62137-62139 [2015-26157]
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Federal Register / Vol. 80, No. 199 / Thursday, October 15, 2015 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76105; File No. SR–FINRA–
2015–022]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving a
Proposed Rule Change To Amend
FINRA Rule 2210 (Communications
With the Public)
October 8, 2015.
I. Introduction
On June 29, 2015, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2 a
proposed rule change to amend FINRA
Rule 2210, Communications With the
Public. The proposed rule change was
published for comment in the Federal
Register on July 13, 2015.3 The
Commission received nine comment
letters on the proposed rule change 4
and a response to the comments from
FINRA.5 On August 13, 2015, FINRA
extended the time period for
Commission action on this proposed
rule change to October 9, 2015. This
order approves the proposed rule
change.
II. Description of the Proposed Rule
Change
FINRA proposes to amend Rule 2210
to require each of its member’s Web
sites to include a readily apparent
reference and hyperlink to
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 75377
(July 7, 2015), 80 FR 40092 (‘‘Notice’’).
4 See letters from David Neuman, Israels Neuman
PLC, dated July 29, 2015 (‘‘Neuman Letter’’); Robert
C. Port, Gaslowitz Frankel LLC, dated August 1,
2015 (‘‘Gaslowitz Letter’’); William Beatty,
President, North American Securities
Administrators Association, Inc., dated August 3,
2015 (‘‘NASAA Letter’’); David T. Bellaire,
Executive Vice President & General Counsel,
Financial Services Institute, dated August 3, 2015
(‘‘FSI Letter’’); Dorothy Donohue, Deputy General
Counsel—Securities Regulation, Investment
Company Institute, dated August 3, 2015 (‘‘ICI
Letter’’); Elissa Germaine, Supervising Attorney and
Jill Gross, Director, Pace Investor Rights Clinic, Pace
Law School, dated August 3, 2015 (‘‘PIRC Letter’’);
Melissa MacGregor, Managing Director and
Associate General Counsel, Securities Industry and
Financial Markets Association, dated August 3,
2015 (‘‘SIFMA Letter’’); Joseph C. Peiffer, President,
Public Investors Arbitration Bar Association, dated
August 3, 2015 (‘‘PIABA Letter’’); and Sutherland
Asbill & Brennan LLP on behalf of the Committee
of Annuity Insurers, dated August 3, 2015 (‘‘CAI
Letter’’).
5 See letter from Jeanette Wingler, Assistant
General Counsel, FINRA, dated September 21, 2015
(‘‘FINRA Letter’’).
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BrokerCheck 6 on: (i) The initial Web
page that the member intends to be
viewed by retail investors; and (ii) any
other Web page that includes a
professional profile of one or more
registered persons who conducts
business with retail investors. These
requirements would not apply to a
member that does not provide products
or services to retail investors, or to a
directory or list of registered persons
limited to names and contact
information.
III. Comment Letters
Commenters generally support
FINRA’s proposal.7 As discussed below,
some commenters recommend that the
proposal be expanded and include
additional requirements, and some
request additional guidance regarding
the application of the proposal.
Requests for Additional Requirements
Some commenters state that FINRA
should require a reference and
hyperlink to BrokerCheck in members’
and registered persons’ emails and
account statements to customers.8 In its
response letter, FINRA states that it did
not propose these requirements because
at this time FINRA believes such
requirements would be overly
burdensome and require significant
system and operational changes without
commensurate benefits.9 Some
commenters state that FINRA should
require firms to include BrokerCheck
links on certain third party Web sites.10
In response, FINRA states that it
recognizes the difficulties and costs
associated with including links on
third-party Web sites, and therefore has
determined to limit the application of
the proposed rule to members’ Web sites
at this time.11 However, FINRA notes
that it will continue to monitor
investors’ awareness and use of
BrokerCheck and consider whether to
pursue further rulemaking.12
6 BrokerCheck provides the public with
information on the professional background,
business practices, and conduct of FINRA members
and their associated persons. The information that
FINRA releases through BrokerCheck is derived
from the Central Registration Depository (‘‘CRD’’),
the securities industry online registration and
licensing database.
7 See Neuman Letter; Gaslowitz Letter; ICI Letter
at 1 and 3; SIFMA Letter at 1; PIRC Letter at 1;
NASAA Letter at 1; FSI Letter at 1; and PIABA
Letter at 1.
8 See Neuman Letter and PIRC Letter at 1–2. See
also NASAA Letter at 2.
9 See FINRA Letter at 3.
10 See PIRC Letter at 1–2; NASAA Letter at 2; and
PIABA Letter at 1–2. But see, e.g., SIFMA Letter at
2 and FSI Letter at 1 (both supporting the exclusion
of third-party Web sites).
11 See FINRA Letter at 3.
12 See id.
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62137
Some commenters state that FINRA
should require deep links to firms’ and
individuals’ BrokerCheck reports.13 In
response, FINRA states while it has
determined not to include deep links at
this time, most investors should be able
to find information concerning
particular members and registered
representatives without difficulty given
the ease of operation of the BrokerCheck
search feature.14 FINRA also states that,
while the proposed rule does not
require deep links, it does not prohibit
members from using deep links.15
Finally, some commenters note that
BrokerCheck excludes certain
information that is currently available
on the CRD system, and state that
investors should be able to view all
relevant information that is available in
the CRD system.16 FINRA notes that
these comments are outside the scope of
the current proposal, but that it
regularly assesses the BrokerCheck
program and may consider including
additional information in BrokerCheck
at a later time.17
Requests for Additional Guidance
Two commenters seek guidance
regarding the interpretation of the term
‘‘readily apparent’’ as used the proposed
rule, including whether placing the link
to BrokerCheck in a Web site’s footer
would satisfy the ‘‘readily apparent’’
requirement.18 One commenter seeks
guidance regarding the placement of the
BrokerCheck reference and hyperlink on
Web sites that are optimized for mobile
devices.19 One commenter requests
confirmation that ‘‘readily apparent
reference’’ is not meant to be an
extensive disclosure and that a firm can
simply reference the term BrokerCheck
without any accompanying disclosure.20
Another commenter seeks confirmation
that language such as ‘‘check the
background of an investment
professional’’ would satisfy the
proposed rule’s ‘‘reference’’
requirement.21 In its response letter,
FINRA states that it is unable to provide
specific guidance regarding what
constitutes a readily apparent reference
and hyperlink given the wide variety of
Web pages that its members maintain.22
13 See PIRC Letter at 1; NASAA Letter at 1–2; and
PIABA Letter at 1. But see, e.g., FSI Letter at 3
(supporting the exclusion of deep links).
14 See FINRA Letter at 2.
15 See id.
16 See Neuman Letter; PIRC Letter at 2; and
PIABA Letter at 2.
17 See FINRA Letter at 3–4.
18 See SIFMA Letter at 3 and FSI Letter at 4.
19 See SIFMA Letter at 3.
20 See CAI Letter at 2–3.
21 See SIFMA Letter at 3.
22 See FINRA Letter at 6.
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FINRA states, however, that it generally
does not believe that including the
reference and hyperlink in a footer
would satisfy the ‘‘readily apparent’’
standard.23 In addition, FINRA notes
that members have flexibility as to the
location of the BrokerCheck reference
and hyperlink on Web sites that are
optimized for mobile devices, so long as
they are readily apparent.24 Moreover,
FINRA states that it anticipates that the
readily apparent reference to
BrokerCheck would be brief.25
One commenter seeks confirmation
that, for firms that choose to provide the
BrokerCheck link through an icon or
button similar to that used by FINRA,
such use would be a permissible use of
any trademark or related intellectual
property owned by FINRA.26 In
response, FINRA states that it
anticipates making BrokerCheck-related
icons or similar resources available to
members as one option for complying
with the proposed rule, but use of any
such icons or similar resources by
members would be subject to FINRA’s
terms and conditions for use.27
One commenter seeks clarification
regarding the application of the
proposed rule to Web sites maintained
by independent contractor registered
representatives.28 In its response letter,
FINRA states that it expects member
firms to supervise and review for
compliance Web sites operated by a
registered representative that promote
the business of the member and, that for
purposes of Rule 2210, views such Web
sites to be Web sites of the member
firm.29
One commenter seeks confirmation
that, for multi-faceted financial
institutions, the link to BrokerCheck
should be placed on the homepage of
the broker-dealer member firm as
opposed to the enterprise-level
homepage,30 as well as clarification that
the term ‘‘initial Web page that the
member intends to be viewed by retail
investors’’ applies only to the main or
primary homepage of a member firm,
and not to any ‘‘micro-sites’’ or other
sites maintained by the member firm.31
With respect to multi-faceted financial
institutions, FINRA states that the
proposed rule would apply to the
affiliated broker-dealer’s main Web page
but not to the enterprise-level
homepage.32 With respect to microsites, FINRA states that if a micro-site
acts solely as a conduit to the member’s
main Web site that includes a readily
apparent reference and hyperlink to
BrokerCheck, then FINRA generally
would not require a separate hyperlink
and reference to BrokerCheck on the
micro-site. Otherwise, the proposed rule
would require a separate hyperlink and
reference to BrokerCheck on the initial
Web page of the micro-site that the
member intends to be viewed by retail
investors.33
One commenter seeks additional
guidance on the treatment of Web pages
of registered persons and/or branch
offices under the proposal.34 In
response, FINRA states that, if a
separate retail Web site has been
established for a branch office or branch
office personnel, then such a Web site
would be treated as a separate Web site
of the member and would require a
separate hyperlink and reference to
BrokerCheck.35 On the other hand, if
only a sub-page of the member’s Web
site was established for the branch office
or branch office personnel, then such a
Web page would not be treated as a
separate Web site of the member.36
Moreover, FINRA confirms that
hyperlinks and references to
BrokerCheck would be required for all
Web pages where a registered person’s
profile information appears, including
Web pages on the member’s Web site
23 See id. FINRA states that members should
adopt the perspective of a reasonable retail investor
when making a determination regarding the
reference and hyperlink. FINRA states that some of
the factors that members should consider include
placement, font size, and font color. See id. at 6–
7.
24 See id. at 7.
25 See id. at 6.
26 See SIFMA Letter at 3.
27 See FINRA Letter at 7.
28 See SIFMA Letter at 3–4. See also FSI Letter
at 3–4 (asking whether the client-facing Web site of
a financial advisor engaged in an independent
contractor relationship with its broker-dealer would
be considered a ‘‘member Web site’’ or a third-party
Web site under the proposal).
29 See FINRA Letter at 4. See also letter to Gordon
S. Macklin, President, National Association of
Securities Dealers, Inc. from Douglas Scarff,
Director, Division of Market Regulation, dated June
18, 1982, regarding the status of ‘‘independent
contractors.’’
30 See also CAI Letter at 2 (requesting
confirmation that, where a broker-dealer does not
maintain its own independent Web site (as is often
the case with respect to insurance-affiliated brokerdealers), the BrokerCheck link would not be
required on the broker-dealer affiliate’s main Web
page, but rather on the first Web page in which the
broker-dealer is identified).
31 See SIFMA Letter at 4.
32 See FINRA Letter at 4.
33 See id. at 5.
34 See CAI Letter at 2 (noting that including the
BrokerCheck link on the initial page of the branch
Web site would be helpful to investors; however,
the current proposal is unclear on how to treat
additional pages of a branch office Web site and,
in certain circumstances, requiring a BrokerCheck
link on all possible Web pages where a branch
office registered person’s profile information
appears could result in redundant and ineffective
disclosure).
35 See FINRA Letter at 5.
36 See id. at 5–6.
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and Web pages on a branch office’s Web
site.37
One commenter requests guidance
regarding the application of the
proposed rule to third-party Web sites
that contain professional profiles of
financial advisors that engage in a
networking relationship with these third
parties, such as Web sites owned and
operated by credit unions and other
non-FINRA members.38 In response,
FINRA notes that the proposed rule
does not require hyperlinks and
references to BrokerCheck on thirdparty Web sites and, therefore, the
proposed rule would not apply to third
party Web sites that contain the
professional profiles of registered
representatives who engage in
networking or similar relationships with
the third party.39
One commenter requests that FINRA
promulgate a Regulatory Notice to
provide interpretive guidance or
responses to frequently asked questions,
accompanied by a succinct reiteration of
what information is and is not disclosed
through BrokerCheck.40 In response,
FINRA states that its Web site provides
readily available information regarding
the information disclosed through
BrokerCheck.41 This commenter also
requests a limited safe harbor for links
to BrokerCheck that are broken as a
result of script or programming issues
that would permit a reasonable amount
of time to respond to any link
maintenance issues.42 FINRA
acknowledges that links occasionally
may fail, but does not believe that the
requested relief is necessary or
warranted at this time.43 Rather, FINRA
would consider all of the facts and
circumstances surrounding any such
failures.44
One commenter requests a 12-month
implementation period for the
proposal.45 In its response letter, FINRA
recognizes that members would be
required to identify the Web pages that
would need to be updated, determine
where to place the references and
hyperlinks within the Web pages, and
test and deploy the updated Web site.
FINRA stated that it will consider the
need for system and operational changes
37 See
id. at 6.
FSI Letter at 4. See also SIFMA Letter at
4 (seeking clarification regarding the application of
the proposed rule to Web sites of non-member firms
who are parties to a networking or other similar
arrangement with a member firm).
39 See FINRA Letter at 5.
40 See SIFMA Letter at 2–3.
41 See FINRA Letter at 4.
42 See SIFMA Letter at 4.
43 See FINRA Letter at 7.
44 See id.
45 See FSI Letter at 4.
38 See
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Federal Register / Vol. 80, No. 199 / Thursday, October 15, 2015 / Notices
in establishing the effective date for the
proposed rule change.46
IV. Discussion and Commission
Findings
After careful review of the proposed
rule change, the comment letters, and
FINRA’s response to the comments, the
Commission finds that the proposed
rule change is consistent with the
requirements of the Act and the rules
and regulations thereunder that are
applicable to a national securities
association.47 Specifically, the
Commission finds that the proposed
rule change is consistent with Section
15A(b)(6) of the Act,48 which requires,
among other things, that FINRA rules 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. The
proposed rule change, by requiring a
hyperlink to BrokerCheck on members’
Web sites is designed to increase
investors’ awareness and use of
BrokerCheck. BrokerCheck is an
important tool for investors to use to
help them make informed choices about
the individuals and firms with which
they conduct business.49 The
Commission believes that the
requirement for the hyperlink to
BrokerCheck to be readily apparent
should make it easy for investors to find
and use BrokerCheck. The Commission
appreciates FINRA’s continuing efforts
to enhance BrokerCheck and encourages
FINRA to continue improving it and to
consider the suggestions made by
commenters that could result in
increased use of BrokerCheck by the
investing public.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,50 that the
proposed rule change (SR–FINRA–
2015–022) be, and hereby is, approved.
46 See
FINRA Letter at 7.
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).
48 15 U.S.C. 78o–3(b)(6).
49 The Commission encourages investors to
utilize all sources of information, including the
databases of state regulators, as well as legal search
engines and records searches to conduct a thorough
search of any associated person or firm with which
they are considering doing business. See also
Securities Exchange Act Release No. 62476 (July 8,
2010), 75 FR 41254 (July 15, 2010) (SR–FINRA–
2010–012).
50 15 U.S.C. 78s(b)(2).
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For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.51
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–26157 Filed 10–14–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76107; File No. SR–CBOE–
2015–084]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change Relating to Delivery of
the Regulatory Element of the
Exchange’s Continuing Education
Program
October 8, 2015.
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
September 30, 2015, Chicago Board
Options Exchange, Incorporated (the
‘‘Exchange’’ or ‘‘CBOE’’) filed with the
Securities and Exchange Commission
(the ‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared by the Exchange. The
Exchange filed the proposal as a ‘‘noncontroversial’’ proposed rule change
pursuant to Section 19(b)(3)(A)(iii) of
the Act 3 and Rule 19b–4(f)(6)
thereunder.4 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
Rule 9.3A (Continuing Education for
Registered Persons) to provide for Webbased delivery of the Regulatory
Element of the Exchange’s continuing
education (‘‘CE’’) program. The text of
the proposed rule change is available on
the Exchange’s Web site (https://
www.cboe.com/AboutCBOE/
CBOELegalRegulatoryHome.aspx), at
the Exchange’s Office of the Secretary,
and at the Commission’s Public
Reference Room.
51 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(iii).
4 17 CFR 240.19b–4(f)(6).
1 15
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62139
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
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The CE requirements under Rule 9.3A
consist of a Regulatory Element 5 and a
Firm Element.6 The Regulatory Element
applies to all registered persons 7 and
consists of periodic computer-based
training on regulatory, compliance,
ethical, and supervisory subjects and
sales practice standards, which must be
completed within prescribed
timeframes.8 In addition, a registered
person is required to retake the
Regulatory Element in the event that
such person: (i) Becomes subject to any
statutory disqualification as defined in
Section 3(a)(39) of the Securities
Exchange Act of 1934 (the ‘‘Act’’); (ii)
becomes subject to suspension or to the
imposition of a fine of $5,000 or more
for violation of any provision of any
securities law or regulation, or any
agreement with or rule or standard of
conduct of any securities governmental
agency, securities self-regulatory
organization, or as imposed by any such
regulatory or self-regulatory
organization in connection with a
disciplinary proceeding; or (iii) is
5 See
Rule 9.3A(a) (Regulatory Element).
Rule 9.3A(c) (Firm Element).
7 For purposes of the Regulatory Element, a
‘‘registered person’’ means a Trading Permit Holder
(‘‘TPH’’), associated person, and/or Representative
approved by and registered with the Exchange. See
Interpretation and Policy .01 to Rule 9.3A.
8 Pursuant to Rule 9.3A(a), each registered person
shall complete the Regulatory Element of the
continuing education program beginning with the
occurrence of their second registration anniversary
date and every three years thereafter, or as
otherwise prescribed by the Exchange. On each
occasion, the Regulatory Element must be
completed within one hundred twenty days after
the person’s registration anniversary date. A
person’s initial registration date, also known as the
‘‘base date’’, shall establish the cycle of anniversary
dates for purposes of the Rule. The content of the
Regulatory Element of the program shall be
determined by the Exchange for each registration
category of persons subject to the Rule.
6 See
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Agencies
[Federal Register Volume 80, Number 199 (Thursday, October 15, 2015)]
[Notices]
[Pages 62137-62139]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-26157]
[[Page 62137]]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-76105; File No. SR-FINRA-2015-022]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving a Proposed Rule Change To Amend FINRA
Rule 2210 (Communications With the Public)
October 8, 2015.
I. Introduction
On June 29, 2015, the Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change to amend FINRA Rule 2210, Communications With the
Public. The proposed rule change was published for comment in the
Federal Register on July 13, 2015.\3\ The Commission received nine
comment letters on the proposed rule change \4\ and a response to the
comments from FINRA.\5\ On August 13, 2015, FINRA extended the time
period for Commission action on this proposed rule change to October 9,
2015. This order approves the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 75377 (July 7,
2015), 80 FR 40092 (``Notice'').
\4\ See letters from David Neuman, Israels Neuman PLC, dated
July 29, 2015 (``Neuman Letter''); Robert C. Port, Gaslowitz Frankel
LLC, dated August 1, 2015 (``Gaslowitz Letter''); William Beatty,
President, North American Securities Administrators Association,
Inc., dated August 3, 2015 (``NASAA Letter''); David T. Bellaire,
Executive Vice President & General Counsel, Financial Services
Institute, dated August 3, 2015 (``FSI Letter''); Dorothy Donohue,
Deputy General Counsel--Securities Regulation, Investment Company
Institute, dated August 3, 2015 (``ICI Letter''); Elissa Germaine,
Supervising Attorney and Jill Gross, Director, Pace Investor Rights
Clinic, Pace Law School, dated August 3, 2015 (``PIRC Letter'');
Melissa MacGregor, Managing Director and Associate General Counsel,
Securities Industry and Financial Markets Association, dated August
3, 2015 (``SIFMA Letter''); Joseph C. Peiffer, President, Public
Investors Arbitration Bar Association, dated August 3, 2015 (``PIABA
Letter''); and Sutherland Asbill & Brennan LLP on behalf of the
Committee of Annuity Insurers, dated August 3, 2015 (``CAI
Letter'').
\5\ See letter from Jeanette Wingler, Assistant General Counsel,
FINRA, dated September 21, 2015 (``FINRA Letter'').
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II. Description of the Proposed Rule Change
FINRA proposes to amend Rule 2210 to require each of its member's
Web sites to include a readily apparent reference and hyperlink to
BrokerCheck \6\ on: (i) The initial Web page that the member intends to
be viewed by retail investors; and (ii) any other Web page that
includes a professional profile of one or more registered persons who
conducts business with retail investors. These requirements would not
apply to a member that does not provide products or services to retail
investors, or to a directory or list of registered persons limited to
names and contact information.
---------------------------------------------------------------------------
\6\ BrokerCheck provides the public with information on the
professional background, business practices, and conduct of FINRA
members and their associated persons. The information that FINRA
releases through BrokerCheck is derived from the Central
Registration Depository (``CRD''), the securities industry online
registration and licensing database.
---------------------------------------------------------------------------
III. Comment Letters
Commenters generally support FINRA's proposal.\7\ As discussed
below, some commenters recommend that the proposal be expanded and
include additional requirements, and some request additional guidance
regarding the application of the proposal.
---------------------------------------------------------------------------
\7\ See Neuman Letter; Gaslowitz Letter; ICI Letter at 1 and 3;
SIFMA Letter at 1; PIRC Letter at 1; NASAA Letter at 1; FSI Letter
at 1; and PIABA Letter at 1.
---------------------------------------------------------------------------
Requests for Additional Requirements
Some commenters state that FINRA should require a reference and
hyperlink to BrokerCheck in members' and registered persons' emails and
account statements to customers.\8\ In its response letter, FINRA
states that it did not propose these requirements because at this time
FINRA believes such requirements would be overly burdensome and require
significant system and operational changes without commensurate
benefits.\9\ Some commenters state that FINRA should require firms to
include BrokerCheck links on certain third party Web sites.\10\ In
response, FINRA states that it recognizes the difficulties and costs
associated with including links on third-party Web sites, and therefore
has determined to limit the application of the proposed rule to
members' Web sites at this time.\11\ However, FINRA notes that it will
continue to monitor investors' awareness and use of BrokerCheck and
consider whether to pursue further rulemaking.\12\
---------------------------------------------------------------------------
\8\ See Neuman Letter and PIRC Letter at 1-2. See also NASAA
Letter at 2.
\9\ See FINRA Letter at 3.
\10\ See PIRC Letter at 1-2; NASAA Letter at 2; and PIABA Letter
at 1-2. But see, e.g., SIFMA Letter at 2 and FSI Letter at 1 (both
supporting the exclusion of third-party Web sites).
\11\ See FINRA Letter at 3.
\12\ See id.
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Some commenters state that FINRA should require deep links to
firms' and individuals' BrokerCheck reports.\13\ In response, FINRA
states while it has determined not to include deep links at this time,
most investors should be able to find information concerning particular
members and registered representatives without difficulty given the
ease of operation of the BrokerCheck search feature.\14\ FINRA also
states that, while the proposed rule does not require deep links, it
does not prohibit members from using deep links.\15\
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\13\ See PIRC Letter at 1; NASAA Letter at 1-2; and PIABA Letter
at 1. But see, e.g., FSI Letter at 3 (supporting the exclusion of
deep links).
\14\ See FINRA Letter at 2.
\15\ See id.
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Finally, some commenters note that BrokerCheck excludes certain
information that is currently available on the CRD system, and state
that investors should be able to view all relevant information that is
available in the CRD system.\16\ FINRA notes that these comments are
outside the scope of the current proposal, but that it regularly
assesses the BrokerCheck program and may consider including additional
information in BrokerCheck at a later time.\17\
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\16\ See Neuman Letter; PIRC Letter at 2; and PIABA Letter at 2.
\17\ See FINRA Letter at 3-4.
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Requests for Additional Guidance
Two commenters seek guidance regarding the interpretation of the
term ``readily apparent'' as used the proposed rule, including whether
placing the link to BrokerCheck in a Web site's footer would satisfy
the ``readily apparent'' requirement.\18\ One commenter seeks guidance
regarding the placement of the BrokerCheck reference and hyperlink on
Web sites that are optimized for mobile devices.\19\ One commenter
requests confirmation that ``readily apparent reference'' is not meant
to be an extensive disclosure and that a firm can simply reference the
term BrokerCheck without any accompanying disclosure.\20\ Another
commenter seeks confirmation that language such as ``check the
background of an investment professional'' would satisfy the proposed
rule's ``reference'' requirement.\21\ In its response letter, FINRA
states that it is unable to provide specific guidance regarding what
constitutes a readily apparent reference and hyperlink given the wide
variety of Web pages that its members maintain.\22\
[[Page 62138]]
FINRA states, however, that it generally does not believe that
including the reference and hyperlink in a footer would satisfy the
``readily apparent'' standard.\23\ In addition, FINRA notes that
members have flexibility as to the location of the BrokerCheck
reference and hyperlink on Web sites that are optimized for mobile
devices, so long as they are readily apparent.\24\ Moreover, FINRA
states that it anticipates that the readily apparent reference to
BrokerCheck would be brief.\25\
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\18\ See SIFMA Letter at 3 and FSI Letter at 4.
\19\ See SIFMA Letter at 3.
\20\ See CAI Letter at 2-3.
\21\ See SIFMA Letter at 3.
\22\ See FINRA Letter at 6.
\23\ See id. FINRA states that members should adopt the
perspective of a reasonable retail investor when making a
determination regarding the reference and hyperlink. FINRA states
that some of the factors that members should consider include
placement, font size, and font color. See id. at 6-7.
\24\ See id. at 7.
\25\ See id. at 6.
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One commenter seeks confirmation that, for firms that choose to
provide the BrokerCheck link through an icon or button similar to that
used by FINRA, such use would be a permissible use of any trademark or
related intellectual property owned by FINRA.\26\ In response, FINRA
states that it anticipates making BrokerCheck-related icons or similar
resources available to members as one option for complying with the
proposed rule, but use of any such icons or similar resources by
members would be subject to FINRA's terms and conditions for use.\27\
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\26\ See SIFMA Letter at 3.
\27\ See FINRA Letter at 7.
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One commenter seeks clarification regarding the application of the
proposed rule to Web sites maintained by independent contractor
registered representatives.\28\ In its response letter, FINRA states
that it expects member firms to supervise and review for compliance Web
sites operated by a registered representative that promote the business
of the member and, that for purposes of Rule 2210, views such Web sites
to be Web sites of the member firm.\29\
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\28\ See SIFMA Letter at 3-4. See also FSI Letter at 3-4 (asking
whether the client-facing Web site of a financial advisor engaged in
an independent contractor relationship with its broker-dealer would
be considered a ``member Web site'' or a third-party Web site under
the proposal).
\29\ See FINRA Letter at 4. See also letter to Gordon S.
Macklin, President, National Association of Securities Dealers, Inc.
from Douglas Scarff, Director, Division of Market Regulation, dated
June 18, 1982, regarding the status of ``independent contractors.''
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One commenter seeks confirmation that, for multi-faceted financial
institutions, the link to BrokerCheck should be placed on the homepage
of the broker-dealer member firm as opposed to the enterprise-level
homepage,\30\ as well as clarification that the term ``initial Web page
that the member intends to be viewed by retail investors'' applies only
to the main or primary homepage of a member firm, and not to any
``micro-sites'' or other sites maintained by the member firm.\31\ With
respect to multi-faceted financial institutions, FINRA states that the
proposed rule would apply to the affiliated broker-dealer's main Web
page but not to the enterprise-level homepage.\32\ With respect to
micro-sites, FINRA states that if a micro-site acts solely as a conduit
to the member's main Web site that includes a readily apparent
reference and hyperlink to BrokerCheck, then FINRA generally would not
require a separate hyperlink and reference to BrokerCheck on the micro-
site. Otherwise, the proposed rule would require a separate hyperlink
and reference to BrokerCheck on the initial Web page of the micro-site
that the member intends to be viewed by retail investors.\33\
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\30\ See also CAI Letter at 2 (requesting confirmation that,
where a broker-dealer does not maintain its own independent Web site
(as is often the case with respect to insurance-affiliated broker-
dealers), the BrokerCheck link would not be required on the broker-
dealer affiliate's main Web page, but rather on the first Web page
in which the broker-dealer is identified).
\31\ See SIFMA Letter at 4.
\32\ See FINRA Letter at 4.
\33\ See id. at 5.
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One commenter seeks additional guidance on the treatment of Web
pages of registered persons and/or branch offices under the
proposal.\34\ In response, FINRA states that, if a separate retail Web
site has been established for a branch office or branch office
personnel, then such a Web site would be treated as a separate Web site
of the member and would require a separate hyperlink and reference to
BrokerCheck.\35\ On the other hand, if only a sub-page of the member's
Web site was established for the branch office or branch office
personnel, then such a Web page would not be treated as a separate Web
site of the member.\36\ Moreover, FINRA confirms that hyperlinks and
references to BrokerCheck would be required for all Web pages where a
registered person's profile information appears, including Web pages on
the member's Web site and Web pages on a branch office's Web site.\37\
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\34\ See CAI Letter at 2 (noting that including the BrokerCheck
link on the initial page of the branch Web site would be helpful to
investors; however, the current proposal is unclear on how to treat
additional pages of a branch office Web site and, in certain
circumstances, requiring a BrokerCheck link on all possible Web
pages where a branch office registered person's profile information
appears could result in redundant and ineffective disclosure).
\35\ See FINRA Letter at 5.
\36\ See id. at 5-6.
\37\ See id. at 6.
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One commenter requests guidance regarding the application of the
proposed rule to third-party Web sites that contain professional
profiles of financial advisors that engage in a networking relationship
with these third parties, such as Web sites owned and operated by
credit unions and other non-FINRA members.\38\ In response, FINRA notes
that the proposed rule does not require hyperlinks and references to
BrokerCheck on third-party Web sites and, therefore, the proposed rule
would not apply to third party Web sites that contain the professional
profiles of registered representatives who engage in networking or
similar relationships with the third party.\39\
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\38\ See FSI Letter at 4. See also SIFMA Letter at 4 (seeking
clarification regarding the application of the proposed rule to Web
sites of non-member firms who are parties to a networking or other
similar arrangement with a member firm).
\39\ See FINRA Letter at 5.
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One commenter requests that FINRA promulgate a Regulatory Notice to
provide interpretive guidance or responses to frequently asked
questions, accompanied by a succinct reiteration of what information is
and is not disclosed through BrokerCheck.\40\ In response, FINRA states
that its Web site provides readily available information regarding the
information disclosed through BrokerCheck.\41\ This commenter also
requests a limited safe harbor for links to BrokerCheck that are broken
as a result of script or programming issues that would permit a
reasonable amount of time to respond to any link maintenance
issues.\42\ FINRA acknowledges that links occasionally may fail, but
does not believe that the requested relief is necessary or warranted at
this time.\43\ Rather, FINRA would consider all of the facts and
circumstances surrounding any such failures.\44\
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\40\ See SIFMA Letter at 2-3.
\41\ See FINRA Letter at 4.
\42\ See SIFMA Letter at 4.
\43\ See FINRA Letter at 7.
\44\ See id.
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One commenter requests a 12-month implementation period for the
proposal.\45\ In its response letter, FINRA recognizes that members
would be required to identify the Web pages that would need to be
updated, determine where to place the references and hyperlinks within
the Web pages, and test and deploy the updated Web site. FINRA stated
that it will consider the need for system and operational changes
[[Page 62139]]
in establishing the effective date for the proposed rule change.\46\
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\45\ See FSI Letter at 4.
\46\ See FINRA Letter at 7.
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IV. Discussion and Commission Findings
After careful review of the proposed rule change, the comment
letters, and FINRA's response to the comments, the Commission finds
that the proposed rule change is consistent with the requirements of
the Act and the rules and regulations thereunder that are applicable to
a national securities association.\47\ Specifically, the Commission
finds that the proposed rule change is consistent with Section
15A(b)(6) of the Act,\48\ which requires, among other things, that
FINRA rules 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. The proposed
rule change, by requiring a hyperlink to BrokerCheck on members' Web
sites is designed to increase investors' awareness and use of
BrokerCheck. BrokerCheck is an important tool for investors to use to
help them make informed choices about the individuals and firms with
which they conduct business.\49\ The Commission believes that the
requirement for the hyperlink to BrokerCheck to be readily apparent
should make it easy for investors to find and use BrokerCheck. The
Commission appreciates FINRA's continuing efforts to enhance
BrokerCheck and encourages FINRA to continue improving it and to
consider the suggestions made by commenters that could result in
increased use of BrokerCheck by the investing public.
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\47\ 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).
\48\ 15 U.S.C. 78o-3(b)(6).
\49\ The Commission encourages investors to utilize all sources
of information, including the databases of state regulators, as well
as legal search engines and records searches to conduct a thorough
search of any associated person or firm with which they are
considering doing business. See also Securities Exchange Act Release
No. 62476 (July 8, 2010), 75 FR 41254 (July 15, 2010) (SR-FINRA-
2010-012).
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V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\50\ that the proposed rule change (SR-FINRA-2015-022) be, and
hereby is, approved.
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\50\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\51\
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\51\ 17 CFR 200.30-3(a)(12).
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Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015-26157 Filed 10-14-15; 8:45 am]
BILLING CODE 8011-01-P