Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving a Proposed Rule Change Relating to Capital Acquisition Broker Rules 203 (Engaging in Distribution and Solicitation Activities With Government Entities) and 458 (Books and Records Requirements for Government Distribution and Solicitation Activities), 46559-46561 [2017-21413]
Download as PDF
Federal Register / Vol. 82, No. 192 / Thursday, October 5, 2017 / Notices
Member that is rated 7 on the CRRM,
NSCC charges 20 percent of the
Member’s aggregate CNS Fails
Positions.20
NSCC explains that of the 20 percent
charge, 10 percent is imposed pursuant
to Procedure XV, Section I.(A)(1)(f) of
the Rules, which describes NSCC’s
current CNS Fail Charge,21 while the
remaining 10 percent of the charge is
imposed pursuant to Procedure XV,
Section I.(B)(1) of the Rules, which
authorizes NSCC’s to require Members
on the Watch List to make additional
Clearing Fund deposits as determined
by NSCC.22 To clarify NSCC’s current
practices with respect to the assessment
and collection of the CNS Fails Charge
in the Rules, NSCC proposes to amend
the Rules to clearly state that, for any
Member that is rated 7 on the CRRM,
the CNS Fails Charge would be 20
percent of the Member’s aggregate CNS
Fails Positions.23
C. Detailed Description of the Proposed
Rule Changes
To effectuate the proposed change,
NSCC proposes to amend Rule 1 of the
Rules 24 to add a definition for CNS
Fails Position. The proposed definition
would provide that the term ‘‘CNS Fails
Position’’ means either a Long Position
or a Short Position that did not settle on
the Settlement Date.25 NSCC is also
proposing to amend Procedure XV,
Section I.(A)(1)(f) of the Rules to
provide that a Member’s Clearing Fund
contribution shall include an amount
that is calculated by multiplying the
current market value for such Member’s
aggregate CNS Fails Positions by (i) 5
percent for Members rated 1 through 4
on the CRRM; (ii) 10 percent for
Members rated 5 or 6 on the CRRM; or
(iii) 20 percent for Members rated 7 on
the CRRM.26
II. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Act 27
directs the Commission to approve a
proposed rule change of a selfregulatory organization if it finds that
such proposed rule change is consistent
with the requirements of the Act and
rules and regulations thereunder
20 Id.
21 Id.
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22 Notice,
82 FR at 40177.
NSCC states that Members which are not
rated by the CRRM are not subject to the CNS Fails
Charge; however, these Members can be placed on
the Watch List as deemed necessary by NSCC to
protect itself and its Members. Id.
24 Rules, supra note 4.
25 Notice, 82 FR at 40176.
26 Id.
27 15 U.S.C. 78s(b)(2)(C).
23 Id.
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19:52 Oct 04, 2017
Jkt 244001
applicable to such organization. The
Commission believes the proposal is
consistent with Act, specifically Section
17A(b)(3)(F) of the Act and Rule 17Ad–
22(e)(23)(i) 28 under the Act, as
discussed below.
A. Consistency With Section
17A(b)(3)(F)
Section 17A(b)(3)(F) of the Act,
requires, in part, that NSCC’s Rules be
designed to promote the prompt and
accurate clearance and settlement of
securities transactions.29
The proposed rule change would
clarify and provide additional
transparency to NSCC members
regarding NSCC’s current practices
surrounding the assessment and
collection of the CNS Fails Charges
associated with each Member.
Specifically, the proposed Rule would
clearly state that Members with a CRRM
rating of 7 are charged 20 percent of the
Member’s aggregate CNS Fails Positions
(instead of the less transparent approach
of charging 10 percent pursuant to the
CNS Fails Charge and 10 pursuant to a
separate Watch List charge). By doing
so, this proposed rule change would
help the Rules to be more transparent,
accurate, and clear, which would better
enable Members to understand their
respective rights and obligations with
respect to their NSCC membership and,
in turn, support NSCC’s clearance and
settlement of securities transactions.
Therefore, the Commission believes that
the proposed rule change related to the
CNS Fails Charge would promote the
prompt and accurate clearance and
settlement of securities transactions,
consistent with Section 17A(b)(3)(F) of
the Act.30
B. Consistency With Rule 17Ad–
22(e)(23)(i)
Rule 17Ad–22(e)(23)(i) under the Act
requires NSCC to establish, implement,
maintain and enforce written policies
and procedures reasonably designed to
publicly disclose all relevant rules and
material procedures.31
As described above, the proposed rule
change seeks to clarify in NSCC’s Rules
the current practices with respect to the
assessment and collection of the CNS
Fails Charge. Specifically, NSCC
proposes to amend the Rules to include
a definition for CNS Fails Position and
clearly state NSCC’s current practices
regarding the assessment and collection
of the CNS Fails Charge, including the
28 15 U.S.C. 78q–1(b)(3)(F); 17 CFR 240.17Ad–
22(e)(23)(i).
29 15 U.S.C. 78q–1(b)(3)(F).
30 Id.
31 17 CFR 240.17Ad–22(e)(23)(i).
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Sfmt 4703
46559
percentages that NSCC charges Members
according to their CRRM rating. In doing
so, the Commission believes that
proposed rule change would help
promote disclosure of relevant rules and
material procedures relating to the CNS
Fails Charge, consistent with Rule
17Ad–22(e)(23)(i) under the Act.32
III. Conclusion
On the basis of the foregoing, the
Commission finds that the proposal is
consistent with the requirements of the
Act, in particular the requirements of
Section 17A of the Act 33 and the rules
and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act, that
proposed rule change SR–NSCC–2017–
015 be, and hereby is, approved.34
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.35
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017–21409 Filed 10–4–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–81781; File No. SR–FINRA–
2017–027]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving a
Proposed Rule Change Relating to
Capital Acquisition Broker Rules 203
(Engaging in Distribution and
Solicitation Activities With
Government Entities) and 458 (Books
and Records Requirements for
Government Distribution and
Solicitation Activities)
September 29, 2017.
I. Introduction
On August 17, 2017, 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
(‘‘Exchange Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
adopt Capital Acquisition Broker Rules
203 (Engaging in Distribution and
Solicitation Activities with Government
32 Id.
33 15
U.S.C. 78q–1.
approving the proposed rule change, the
Commission considered the proposals’ impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
35 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
34 In
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46560
Federal Register / Vol. 82, No. 192 / Thursday, October 5, 2017 / Notices
Entities) and 458 (Books and Records
Requirements for Government
Distribution and Solicitation Activities).
These rules would apply established
‘‘pay-to-play’’ and related recordkeeping
rules to the activities of member firms
that have elected to be governed by the
Capital Acquisition Broker (‘‘CAB’’) 3
Rules and that engage in distribution or
solicitation activities for compensation
with government entities on behalf of
investment advisers.
The proposed rule change was
published for comment in the Federal
Register on August 24, 2017.4 The
public comment period closed on
September 14, 2017. No comment letters
were received in response to the Notice.
This order approves the proposed rule
change.
II. Description of the Proposed Rule
Change
As discussed in the Notice and
described below, the proposed rule
change seeks to clarify that FINRA’s
existing pay-to-play rules and related
recordkeeping requirements apply to
CABs. Under the proposed rules, CABs
would be subject to the same
restrictions designed to halt pay-to-play
practices as non-CAB member firms,
which would effectively allow them to
engage in distribution and solicitation
activities with government entities on
behalf of investment advisers.5
A. Pay-to-Play Rules
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In July 2010, the SEC adopted Rule
206(4)–5 under the Investment Advisers
Act of 1940 addressing pay-to-play
practices by investment advisers (the
‘‘SEC Pay-to-Play Rule’’).6 The SEC Pay3 CABs are member firms that engage in a limited
range of activities, essentially advising companies
and private equity funds on capital raising and
corporate restructuring, and acting as placement
agents for sales of unregistered securities to
institutional investors under limited conditions.
See FINRA Regulatory Notice 16–37 (October 2016),
at 1.
4 See Exchange Act Release No. 81438 (August 17,
2017), 82 FR 40181 (August 24, 2017) (Notice of
Filing of a Proposed Rule Change Relating to
Capital Acquisition Broker Rules 203 and 458)
(‘‘Notice’’).
5 ‘‘Pay-to-play’’ practices typically involve a
person making cash or in-kind political
contributions (or soliciting or coordinating others to
make such contributions) to help finance the
election campaigns of state or local officials as a
quid pro quo for the award of government contracts.
See FINRA Regulatory Notice 16–40 (October 2016)
at 9, note 1.
6 See Investment Advisers Act Release No. 3043
(July 1, 2010), 75 FR 41018 (July 14, 2010) (Political
Contributions by Certain Investment Advisers). See
also Investment Advisers Act Release No. 3221
(June 22, 2011), 76 FR 42950 (July 19, 2011) (Rules
Implementing Amendments to the Investment
Advisers Act of 1940); Investment Advisers Act
Release No. 3418 (June 8, 2012), 77 FR 35263 (June
13, 2012) (Political Contributions by Certain
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19:52 Oct 04, 2017
Jkt 244001
to-Play Rule prohibits, in part, an
investment adviser and its covered
associates from providing or agreeing to
provide, directly or indirectly, payment
to any person to solicit a government
entity for investment advisory services
on behalf of the investment adviser
unless the person is a ‘‘regulated
person.’’ 7 A ‘‘regulated person’’
includes a member firm, provided that:
(a) FINRA rules prohibit member firms
from engaging in distribution or
solicitation activities if political
contributions have been made; and (b)
the SEC finds, by order, that such rules
impose substantially equivalent or more
stringent restrictions on member firms
than the SEC Pay-to-Play Rule imposes
on investment advisers and that such
rules are consistent with the objectives
of the SEC Pay-to-Play Rule.8
Based on the framework of the SEC
Pay-to-Play Rule, FINRA proposed
Rules 2030 and 4580, which establish a
comprehensive regime to regulate the
activities of FINRA member firms that
engage in distribution or solicitation
activities with government entities on
behalf of investment advisers, and to
deter member firms from engaging in
pay-to-play practices.9 The SEC
approved these rules on August 25,
2016,10 and later found that Rule 2030
imposes substantially equivalent or
more stringent restrictions on member
firms than the SEC Pay-to-Play Rule
imposes on investment advisers, and
that it is consistent with the objectives
of the SEC Pay-to-Play Rule.11 Rules
2030 and 4580 became effective on
August 20, 2017.12
B. FINRA CAB Rules
On August 18, 2016, the SEC
approved a separate set of FINRA rules
for firms that meet the definition of a
CAB and that elect to be governed under
this rule set.13 Member firms that elect
Investment Advisers; Ban on Third Party
Solicitation; Extension of Compliance Date).
7 See Investment Advisers Act Rule 206(4)–
5(a)(2)(i)(A), 17 CFR 275.206(4)–5(a)(2)(i)(A).
8 See Investment Advisers Act Rule 206(4)–5(f)(9),
17 CFR 275.206(4)–5(f)(9). A ‘‘regulated person’’
also includes SEC-registered investment advisers
and SEC-registered municipal advisors, subject to
specified conditions.
9 See Securities Exchange Act Release No. 76767
(December 24, 2015), 80 FR 81650 (December 30,
2015).
10 See Securities Exchange Act Release No. 78683
(August 25, 2016), 81 FR 60051 (August 31, 2016).
11 See Investment Advisers Act Release No. 4532
(September 20, 2016), 81 FR 66526 (September 28,
2016).
12 See FINRA Regulatory Notice 16–40 (October
2016).
13 See Securities Exchange Act Release No. 78617
(August 18, 2016), 81 FR 57948 (August 24, 2016)
(Order Approving Rule Change as Modified by
Amendment Nos. 1 and 2 to Adopt FINRA Capital
Acquisition Broker Rules).
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Frm 00085
Fmt 4703
Sfmt 4703
to be governed under the CAB rule set
are not permitted, among other things,
to carry or maintain customer accounts,
handle customers’ funds or securities,
accept customers’ trading orders, or
engage in proprietary trading or marketmaking.
The CAB Rules became effective on
April 14, 2017. In order to provide new
CAB applicants with lead time to apply
for FINRA membership and obtain the
necessary qualifications and
registrations, CAB Rules 101–125
became effective on January 3, 2017.
C. Addition of FINRA Pay-to-Play Rules
to CAB Rulebook
The CAB Rules subject CABs to a
number of FINRA Rules, but do not
expressly provide that FINRA Rules
2030 and 4580 apply to CABs. As
explained by FINRA in the Notice, the
proposed rule change sought to make
clear that CABs are subject to FINRA’s
pay-to-play rule, which would make
CABs, like non-CABs, ‘‘regulated
persons’’ that are subject to restrictions
designed to halt pay-to-play practices
and thus can engage in distribution and
solicitation activities with government
entities on behalf of investment advisers
in accordance with the SEC’s Pay-toPlay Rule.
To make this clarification, FINRA
proposed the addition of CAB Rules 203
and 458 to the CAB rule book. CAB Rule
203 would provide that all capital
acquisition brokers are subject to
existing FINRA Rule 2030. CAB Rule
458 would provide that all capital
acquisition brokers are subject to
existing FINRA Rule 4580.
III. Comment Summary
As noted above, no comment letters
were received on the proposed rule
change.
IV. Discussion and Commission
Findings
After careful review of the proposed
rule change, the Commission finds that
the proposal is consistent with the
requirements of the Exchange Act and
the rules and regulations thereunder
that are applicable to a national
securities association.14 The
Commission finds that the proposed
rule change is consistent with Section
15A(b)(6) of the Exchange Act,15 which
requires, among other things, that
FINRA rules be designed to prevent
fraudulent and manipulative acts and
practices, to promote just and equitable
14 In approving this rule change, the Commission
has considered the rule’s impact on efficiency,
competition, and capital formation. See 15 U.S.C.
78c(f).
15 15 U.S.C. 78o–3(b)(6).
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Federal Register / Vol. 82, No. 192 / Thursday, October 5, 2017 / Notices
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principles of trade, and, in general, to
protect investors and the public interest.
Specifically, the Commission finds that
the proposed rule change is consistent
with the Exchange Act for the reasons
expressed in the Order Approving a
Proposed Rule Change to Adopt FINRA
Rule 2030—namely, that this proposed
rule will discourage CABs, like nonCAB member firms, from engaging in
pay-to-play practices that may create
market distortions, impede a free and
open market, and harm investors and
the public interest.16
The Commission agrees with FINRA
that the proposed rule change will
clarify that CABs and non-CAB member
firms are subject to the same rule regime
as they engage in distribution or
solicitation activities with government
entities on behalf of investment
advisers. Without the proposed rule
change, under the SEC’s Pay-to-Play
Rule, CABs could not be retained by
investment advisers to engage in
distribution and solicitation activities
with government entities on their behalf
because the rule set for CABs does not
expressly provide that FINRA Rule 2030
applies to CABs. The Commission also
agrees with FINRA that having such
rules in place will deter CABs from
engaging in pay-to-play practices, and
that clarifying the application of FINRA
Rules 2030 and 4580 to CABs is a more
effective regulatory response to
concerns regarding third-party
solicitations than an outright ban on
such activity.
Lastly, the Commission agrees with
FINRA that the proposed rule change
will not result in any burden on
competition that is not necessary or
appropriate in furtherance of the
purposes of the Exchange Act. In the
Notice, FINRA explained that the
proposed rule change would subject
CABs to the same pay-to-play rules as
non-CAB member firms, and therefore,
the economic impacts associated with
the proposal were contemplated in the
Economic Impact Assessment
accompanying the filing of FINRA Rules
2030 and 4580. FINRA’s Economic
Impact Assessment in the Proposing
Release for FINRA Rules 2030 and 4580
considered the impact on all FINRA
member firms, including firms that at
that time engaged solely in activities
that were later deemed permissible for
CABs.17
16 See Securities Exchange Act Release No. 78683
(August 25, 2016), 81 FR at 60063 (August 31,
2016).
17 See Securities Exchange Act Release No. 76767
(December 24, 2015), 80 FR 81650, 81656–81658
(December 30, 2015) (at the time of the Economic
Impact Assessment, the SEC had not approved the
separate set of rules for CABs).
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19:52 Oct 04, 2017
Jkt 244001
Taking into consideration the
foregoing, the Commission believes that
the proposal is consistent with the
Exchange Act. The Commission believes
that the proposal will help protect
investors and the public interest by,
among other things, clarifying that CABs
and non-CAB member firms are subject
to the same rule regime as they engage
in distribution or solicitation activities
with government entities on behalf of
investment advisers, and by deterring
pay-to-play practices. Accordingly, the
Commission believes that the approach
proposed by FINRA is appropriate and
designed to protect investors and the
public interest, consistent with Section
15A(b)(6) of the Exchange Act and the
rules and regulations thereunder.
V. Conclusion
It is therefore ordered pursuant to
Section 19(b)(2) of the Exchange Act 18
that the proposal (SR–FINRA–2017–
027), be and hereby is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.19
Eduardo A. Aleman
Assistant Secretary.
46561
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
CHX proposes to amend the Rules of
the Exchange (‘‘CHX Rules’’) related to
Sponsored Access. The text of this
proposed rule change is available on the
Exchange’s Web site at (www.chx.com)
and in 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
CHX included statements concerning
the purpose of and basis for the
proposed rule changes 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
CHX has prepared summaries, set forth
in sections A, B and C below, of the
most significant aspects of such
statements.
[FR Doc. 2017–21413 Filed 10–4–17; 8:45 am]
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Changes
BILLING CODE 8011–01–P
1. Purpose
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–81764; File No. SR–CHX–
2017–13]
Self-Regulatory Organizations;
Chicago Stock Exchange, Inc.; Notice
of Filing and Immediate Effectiveness
of Proposed Rule Change Related to
Sponsored Access
September 29, 2017.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 2 thereunder,
notice is hereby given that on
September 15, 2017, the Chicago Stock
Exchange, Inc. (‘‘CHX’’ or the
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
18 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
19 17
PO 00000
Frm 00086
Fmt 4703
Sfmt 4703
The Exchange proposes to amend
CHX Rules to effect the following
changes:
• Amend Article 1, Rule 1 to adopt
the following defined terms:
‘‘Sponsoring Participant,’’ ‘‘Sponsored
Person’’ and ‘‘Sponsored Access.’’
• Amend Article 5, Rule 3 to permit
Sponsoring Participants to provide
Sponsored Access to the Exchange to
Sponsored Persons, subject to enhanced
requirements. Current Article 5, Rule 3
only permits Sponsoring Participants to
provide authorized access to the
Exchange’s trading facilities to nonParticipant 3 broker-dealers. The
proposal would permit Participants,
non-Participants, broker-dealers and
firms that are not broker-dealers to
receive Sponsored Access to the
Exchange.4
3 A ‘‘Participant’’ is a ‘‘member’’ of the Exchange
for the purposes of the Act. See CHX Article 1, Rule
1(s).
4 The Exchange notes that Nasdaq Stock Market
(‘‘Nasdaq’’) permits its members to provide
Sponsored Access to a ‘‘Sponsored Participant,’’
which may be a non-broker-dealer, subject to the
requirements of Nasdaq Rule 4615. According to
Nasdaq, a ‘‘Sponsored Participant’’ may be a
member, non-member, a broker-dealer or not a
broker-dealer, such as ‘‘a hedge fund, mutual fund,
bank or insurance company.’’ See Exchange Act
Release No. 76449 (November 17, 2015), 80 FR
73011, 73012 (November 23, 2015) (SR–NASDAQ–
2015–140).
E:\FR\FM\05OCN1.SGM
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Agencies
[Federal Register Volume 82, Number 192 (Thursday, October 5, 2017)]
[Notices]
[Pages 46559-46561]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-21413]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-81781; File No. SR-FINRA-2017-027]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving a Proposed Rule Change Relating to
Capital Acquisition Broker Rules 203 (Engaging in Distribution and
Solicitation Activities With Government Entities) and 458 (Books and
Records Requirements for Government Distribution and Solicitation
Activities)
September 29, 2017.
I. Introduction
On August 17, 2017, 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 (``Exchange Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to adopt Capital Acquisition
Broker Rules 203 (Engaging in Distribution and Solicitation Activities
with Government
[[Page 46560]]
Entities) and 458 (Books and Records Requirements for Government
Distribution and Solicitation Activities). These rules would apply
established ``pay-to-play'' and related recordkeeping rules to the
activities of member firms that have elected to be governed by the
Capital Acquisition Broker (``CAB'') \3\ Rules and that engage in
distribution or solicitation activities for compensation with
government entities on behalf of investment advisers.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ CABs are member firms that engage in a limited range of
activities, essentially advising companies and private equity funds
on capital raising and corporate restructuring, and acting as
placement agents for sales of unregistered securities to
institutional investors under limited conditions. See FINRA
Regulatory Notice 16-37 (October 2016), at 1.
---------------------------------------------------------------------------
The proposed rule change was published for comment in the Federal
Register on August 24, 2017.\4\ The public comment period closed on
September 14, 2017. No comment letters were received in response to the
Notice. This order approves the proposed rule change.
---------------------------------------------------------------------------
\4\ See Exchange Act Release No. 81438 (August 17, 2017), 82 FR
40181 (August 24, 2017) (Notice of Filing of a Proposed Rule Change
Relating to Capital Acquisition Broker Rules 203 and 458)
(``Notice'').
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
As discussed in the Notice and described below, the proposed rule
change seeks to clarify that FINRA's existing pay-to-play rules and
related recordkeeping requirements apply to CABs. Under the proposed
rules, CABs would be subject to the same restrictions designed to halt
pay-to-play practices as non-CAB member firms, which would effectively
allow them to engage in distribution and solicitation activities with
government entities on behalf of investment advisers.\5\
---------------------------------------------------------------------------
\5\ ``Pay-to-play'' practices typically involve a person making
cash or in-kind political contributions (or soliciting or
coordinating others to make such contributions) to help finance the
election campaigns of state or local officials as a quid pro quo for
the award of government contracts. See FINRA Regulatory Notice 16-40
(October 2016) at 9, note 1.
---------------------------------------------------------------------------
A. Pay-to-Play Rules
In July 2010, the SEC adopted Rule 206(4)-5 under the Investment
Advisers Act of 1940 addressing pay-to-play practices by investment
advisers (the ``SEC Pay-to-Play Rule'').\6\ The SEC Pay-to-Play Rule
prohibits, in part, an investment adviser and its covered associates
from providing or agreeing to provide, directly or indirectly, payment
to any person to solicit a government entity for investment advisory
services on behalf of the investment adviser unless the person is a
``regulated person.'' \7\ A ``regulated person'' includes a member
firm, provided that: (a) FINRA rules prohibit member firms from
engaging in distribution or solicitation activities if political
contributions have been made; and (b) the SEC finds, by order, that
such rules impose substantially equivalent or more stringent
restrictions on member firms than the SEC Pay-to-Play Rule imposes on
investment advisers and that such rules are consistent with the
objectives of the SEC Pay-to-Play Rule.\8\
---------------------------------------------------------------------------
\6\ See Investment Advisers Act Release No. 3043 (July 1, 2010),
75 FR 41018 (July 14, 2010) (Political Contributions by Certain
Investment Advisers). See also Investment Advisers Act Release No.
3221 (June 22, 2011), 76 FR 42950 (July 19, 2011) (Rules
Implementing Amendments to the Investment Advisers Act of 1940);
Investment Advisers Act Release No. 3418 (June 8, 2012), 77 FR 35263
(June 13, 2012) (Political Contributions by Certain Investment
Advisers; Ban on Third Party Solicitation; Extension of Compliance
Date).
\7\ See Investment Advisers Act Rule 206(4)-5(a)(2)(i)(A), 17
CFR 275.206(4)-5(a)(2)(i)(A).
\8\ See Investment Advisers Act Rule 206(4)-5(f)(9), 17 CFR
275.206(4)-5(f)(9). A ``regulated person'' also includes SEC-
registered investment advisers and SEC-registered municipal
advisors, subject to specified conditions.
---------------------------------------------------------------------------
Based on the framework of the SEC Pay-to-Play Rule, FINRA proposed
Rules 2030 and 4580, which establish a comprehensive regime to regulate
the activities of FINRA member firms that engage in distribution or
solicitation activities with government entities on behalf of
investment advisers, and to deter member firms from engaging in pay-to-
play practices.\9\ The SEC approved these rules on August 25, 2016,\10\
and later found that Rule 2030 imposes substantially equivalent or more
stringent restrictions on member firms than the SEC Pay-to-Play Rule
imposes on investment advisers, and that it is consistent with the
objectives of the SEC Pay-to-Play Rule.\11\ Rules 2030 and 4580 became
effective on August 20, 2017.\12\
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\9\ See Securities Exchange Act Release No. 76767 (December 24,
2015), 80 FR 81650 (December 30, 2015).
\10\ See Securities Exchange Act Release No. 78683 (August 25,
2016), 81 FR 60051 (August 31, 2016).
\11\ See Investment Advisers Act Release No. 4532 (September 20,
2016), 81 FR 66526 (September 28, 2016).
\12\ See FINRA Regulatory Notice 16-40 (October 2016).
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B. FINRA CAB Rules
On August 18, 2016, the SEC approved a separate set of FINRA rules
for firms that meet the definition of a CAB and that elect to be
governed under this rule set.\13\ Member firms that elect to be
governed under the CAB rule set are not permitted, among other things,
to carry or maintain customer accounts, handle customers' funds or
securities, accept customers' trading orders, or engage in proprietary
trading or market-making.
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\13\ See Securities Exchange Act Release No. 78617 (August 18,
2016), 81 FR 57948 (August 24, 2016) (Order Approving Rule Change as
Modified by Amendment Nos. 1 and 2 to Adopt FINRA Capital
Acquisition Broker Rules).
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The CAB Rules became effective on April 14, 2017. In order to
provide new CAB applicants with lead time to apply for FINRA membership
and obtain the necessary qualifications and registrations, CAB Rules
101-125 became effective on January 3, 2017.
C. Addition of FINRA Pay-to-Play Rules to CAB Rulebook
The CAB Rules subject CABs to a number of FINRA Rules, but do not
expressly provide that FINRA Rules 2030 and 4580 apply to CABs. As
explained by FINRA in the Notice, the proposed rule change sought to
make clear that CABs are subject to FINRA's pay-to-play rule, which
would make CABs, like non-CABs, ``regulated persons'' that are subject
to restrictions designed to halt pay-to-play practices and thus can
engage in distribution and solicitation activities with government
entities on behalf of investment advisers in accordance with the SEC's
Pay-to-Play Rule.
To make this clarification, FINRA proposed the addition of CAB
Rules 203 and 458 to the CAB rule book. CAB Rule 203 would provide that
all capital acquisition brokers are subject to existing FINRA Rule
2030. CAB Rule 458 would provide that all capital acquisition brokers
are subject to existing FINRA Rule 4580.
III. Comment Summary
As noted above, no comment letters were received on the proposed
rule change.
IV. Discussion and Commission Findings
After careful review of the proposed rule change, the Commission
finds that the proposal is consistent with the requirements of the
Exchange Act and the rules and regulations thereunder that are
applicable to a national securities association.\14\ The Commission
finds that the proposed rule change is consistent with Section
15A(b)(6) of the Exchange Act,\15\ which requires, among other things,
that FINRA rules be designed to prevent fraudulent and manipulative
acts and practices, to promote just and equitable
[[Page 46561]]
principles of trade, and, in general, to protect investors and the
public interest. Specifically, the Commission finds that the proposed
rule change is consistent with the Exchange Act for the reasons
expressed in the Order Approving a Proposed Rule Change to Adopt FINRA
Rule 2030--namely, that this proposed rule will discourage CABs, like
non-CAB member firms, from engaging in pay-to-play practices that may
create market distortions, impede a free and open market, and harm
investors and the public interest.\16\
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\14\ In approving this rule change, the Commission has
considered the rule's impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
\15\ 15 U.S.C. 78o-3(b)(6).
\16\ See Securities Exchange Act Release No. 78683 (August 25,
2016), 81 FR at 60063 (August 31, 2016).
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The Commission agrees with FINRA that the proposed rule change will
clarify that CABs and non-CAB member firms are subject to the same rule
regime as they engage in distribution or solicitation activities with
government entities on behalf of investment advisers. Without the
proposed rule change, under the SEC's Pay-to-Play Rule, CABs could not
be retained by investment advisers to engage in distribution and
solicitation activities with government entities on their behalf
because the rule set for CABs does not expressly provide that FINRA
Rule 2030 applies to CABs. The Commission also agrees with FINRA that
having such rules in place will deter CABs from engaging in pay-to-play
practices, and that clarifying the application of FINRA Rules 2030 and
4580 to CABs is a more effective regulatory response to concerns
regarding third-party solicitations than an outright ban on such
activity.
Lastly, the Commission agrees with FINRA that the proposed rule
change will not result in any burden on competition that is not
necessary or appropriate in furtherance of the purposes of the Exchange
Act. In the Notice, FINRA explained that the proposed rule change would
subject CABs to the same pay-to-play rules as non-CAB member firms, and
therefore, the economic impacts associated with the proposal were
contemplated in the Economic Impact Assessment accompanying the filing
of FINRA Rules 2030 and 4580. FINRA's Economic Impact Assessment in the
Proposing Release for FINRA Rules 2030 and 4580 considered the impact
on all FINRA member firms, including firms that at that time engaged
solely in activities that were later deemed permissible for CABs.\17\
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\17\ See Securities Exchange Act Release No. 76767 (December 24,
2015), 80 FR 81650, 81656-81658 (December 30, 2015) (at the time of
the Economic Impact Assessment, the SEC had not approved the
separate set of rules for CABs).
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Taking into consideration the foregoing, the Commission believes
that the proposal is consistent with the Exchange Act. The Commission
believes that the proposal will help protect investors and the public
interest by, among other things, clarifying that CABs and non-CAB
member firms are subject to the same rule regime as they engage in
distribution or solicitation activities with government entities on
behalf of investment advisers, and by deterring pay-to-play practices.
Accordingly, the Commission believes that the approach proposed by
FINRA is appropriate and designed to protect investors and the public
interest, consistent with Section 15A(b)(6) of the Exchange Act and the
rules and regulations thereunder.
V. Conclusion
It is therefore ordered pursuant to Section 19(b)(2) of the
Exchange Act \18\ that the proposal (SR-FINRA-2017-027), be and hereby
is approved.
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\18\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\19\
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\19\ 17 CFR 200.30-3(a)(12).
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Eduardo A. Aleman
Assistant Secretary.
[FR Doc. 2017-21413 Filed 10-4-17; 8:45 am]
BILLING CODE 8011-01-P