Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Approving Proposed Rule Change To Amend the By-Laws of FINRA Regulation, Inc. To Align the Grounds for Member Removal From the NAC With an Existing Provision in the FINRA By-Laws, 9110-9112 [2021-02779]
Download as PDF
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Federal Register / Vol. 86, No. 27 / Thursday, February 11, 2021 / Notices
Program should be modified,
discontinued, extended, or permanently
approved. Furthermore, the Exchange’s
ongoing analysis of the P.M. Pilot
Program should help it monitor any
potential risks from large P.M.-settled
positions and take appropriate action on
a timely basis if warranted.
The Exchange represents that it has
adequate surveillance procedures to
monitor trading in these options thereby
helping to ensure the maintenance of a
fair and orderly market 16 and has
represented that it has sufficient
capacity to handle additional traffic
associated with this new listing.17
For the reasons discussed above, the
Commission finds that Cboe’s proposal
is consistent with the Act, including
Section 6(b)(5) thereof, in that it is
designed to remove impediments to and
perfect the mechanism of a free and
open market, and, in general, to protect
investors and the public interest. In
light of the enhanced closing procedures
at the underlying markets and the
potential benefits to investors discussed
by the Exchange in the Notice,18 the
Commission finds that it is appropriate
and consistent with the Act to approve
Cboe’s proposal on a pilot basis. The
collection of data during the P.M. Pilot
Program and Cboe’s active monitoring of
any effects of P.M.-settled MRUT
options on the markets will help Cboe
and the Commission assess any impact
of P.M. settlement in today’s market.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,19 that the
proposed rule change (SR–CBOE–2020–
116), as modified by Amendment No. 1,
be, and hereby is, approved, subject to
a pilot period set to expire on May 3,
2021.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.20
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021–02780 Filed 2–10–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–91070; File No. SR–FINRA–
2020–037]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving
Proposed Rule Change To Amend the
By-Laws of FINRA Regulation, Inc. To
Align the Grounds for Member
Removal From the NAC With an
Existing Provision in the FINRA ByLaws
February 5, 2021.
I. Introduction
On October 22, 2020, 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 (the
‘‘Act’’ or ‘‘Exchange Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend a provision in the ByLaws of FINRA Regulation, Inc.
(‘‘FINRA Regulation’’), FINRA’s
regulatory subsidiary. The proposed
rule change would further align the
grounds in the FINRA Regulation ByLaws for removal of a member from the
National Adjudicatory Council (‘‘NAC’’)
with an existing provision in the FINRA
By-Laws for removal of a governor from
the FINRA Board of Governors (‘‘FINRA
Board’’).3
The proposed rule change was
published for comment in the Federal
Register on November 9, 2020.4 The
Commission received no comments on
the proposed rule change. This order
approves the proposed rule change.
II. Description of the Proposal
As described in the Notice, FINRA
Regulation is the regulatory subsidiary
of FINRA and operates according to the
Plan of Allocation and Delegation of
Functions by FINRA to Subsidiaries (the
‘‘Plan’’).5 The FINRA Regulation ByLaws authorize the NAC to function on
behalf of the FINRA Board in several
capacities.6 For example, FINRA
explains that the NAC presides over
disciplinary matters that have been
appealed to or called for review by the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See infra Section II.
4 See Exchange Act Release No. 90324 (November
3, 2020), 85 FR 71387 (November 9, 2020) (File No.
SR–FINRA–2020–037) (the ‘‘Notice’’).
5 See id. at 71388, n.4 (citing the Plan, Sec. II.,
FINRA Regulation, Inc., https://www.finra.org/
rules-guidance/rulebooks/corporate-organization/iifinra-regulation-inc).
6 See id. (citing Article V, Sec. 5.1 of the FINRA
Regulation By-Laws).
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2 17
16 See
Amendment No. 1, supra note 4.
Notice, supra note 3 at 85754.
18 See Notice, supra note 3 at 85755.
19 15 U.S.C. 78s(b)(2).
20 17 CFR 200.30–3(a)(12).
17 See
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NAC and also acts on applications in
statutory disqualification and
membership proceedings.7 In most
matters that the NAC considers, FINRA
states that the NAC prepares proposed
written decisions that become final
FINRA action if the FINRA Board does
not call for review of those decisions.8
FINRA also states that it periodically
reviews its and FINRA Regulation’s ByLaws to ensure adherence to effective
governance practices.9 Based on that
review, FINRA explains that currently,
Article V, Section 5.8 of the FINRA
Regulation By-Laws provides that,
‘‘[a]ny or all of the members of the
[NAC] may be removed from office at
any time for refusal, failure, neglect, or
inability to discharge the duties of such
office by majority vote of the FINRA
Board.’’ 10 By comparison, however, the
FINRA By-Laws provide that a governor
may be removed for those grounds as
well as ‘‘for any cause affecting the best
interests of [FINRA] the sufficiency of
which the Board shall be the sole
judge.’’ 11 As a result, FINRA proposes
to amend the FINRA Regulation ByLaws to add this ground for removal of
a NAC member to further align the bases
for removal of a NAC member with the
bases for removal of a FINRA Board
governor.12 Specifically, the proposed
rule change would amend the FINRA
Regulation By-Laws to permit a NAC
member to be removed by a majority
vote of the FINRA Board ‘‘for any cause
affecting the best interests of the [NAC]
the sufficiency of which the FINRA
Board shall be the sole judge.’’ 13
FINRA further explains that the
removal of a NAC member would
continue to require a majority vote of
the FINRA Board, while a vote to
remove a FINRA Board governor
requires a two-thirds vote.14 In
7 See id. FINRA states that the NAC also exercises
exemption authority and acts in other proceedings
as set forth in the FINRA Rule 9000 Series (Code
of Procedure). The FINRA Board may also delegate
other powers and duties to the NAC as the FINRA
Board deems appropriate and in a manner not
inconsistent with the Plan. See id.
8 See id.
9 See id.
10 See id. As FINRA explains, the FINRA
Regulation By-Laws were amended in 2008 to,
among other things, designate the FINRA Board as
the body authorized to oversee the NAC and
empowered to remove NAC members for the
grounds mentioned above. See id. (citing Exchange
Act Release No. 58909 (November 6, 2008), 73 FR
68467 (November 18, 2008) (Order Approving File
No. SR–FINRA–2008–046) (the ‘‘FINRA Regulation
By-Laws Approval Order’’).
11 See id. Compare Article VII, Section 1(b) of the
FINRA By-Laws, with Article V, Sec. 5.8 of the
FINRA Regulation By-Laws.
12 See Notice, 85 FR at 71388.
13 See id.
14 See id. As FINRA notes, both FINRA and
FINRA Regulation are corporations organized under
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discussing this difference between
voting thresholds for removal, FINRA
states that the higher voting standard for
the removal of a governor reflects the
historical standard that existed at the
National Association of Securities
Dealers (‘‘NASD’’) prior to the formation
of FINRA, and that it provides an
additional safeguard at the FINRA Board
level ‘‘to ensure a diverse, majority nonindustry composition, and fair
representation of the industry in
governance matters.’’ 15
FINRA also states that, given the
NAC’s adjudicatory role, the best
interests of the NAC are more targeted
than the best interests of FINRA.16 More
specifically, FINRA explains that the
best interests of the NAC are reflected in
conduct and attributes that ensure that
the NAC remains an unbiased and
competent adjudicatory body that is free
of conflicts of interest, that its members
conduct themselves with integrity, and
that its decisions are rendered fairly and
consistently with the law and rules that
govern FINRA members and their
associated persons.17 FINRA also states
that the FINRA Board’s decision to
remove a NAC member is a facts and
circumstances determination.18 In
considering whether to remove a NAC
member for cause affecting the best
interests of the NAC, FINRA explains
that its Board may consider, among
other things, the NAC member’s
adherence to general standards
concerning actual and apparent
adjudicator conflicts of interest and
bias,19 and to the NAC’s Conflict of
Interest and Bias Policy, which sets
forth broad-based principles of behavior
that are expected from NAC members.20
Delaware law. The Delaware General Corporation
Law provides that, in general, directors may be
removed by a majority vote of the shares then
entitled to vote at an election of directors. See Del.
Code Ann. Tit. 8, § 141(k). FINRA states that it has
adopted a removal threshold for NAC members that
is consistent with the Delaware General Corporation
Law, although the NAC is not subject to this
standard. See Notice, 85 FR at 71388, n.9.
15 Notice, 85 FR at 71388. FINRA also notes that
the provision of the FINRA Regulation By-Laws
addressing the composition of the NAC also
provides for a diverse, majority non-industry
composition, and for the fair representation of the
industry. See id. at n.10 (citing Article V, Section
5.2(a) of the FINRA Regulation By-Laws and
Exchange Act Release No. 78094 (June 17, 2016), 81
FR 40932, 40934–35 (June 23, 2016)).
16 See id.
17 See id.
18 See id. at 71388–89.
19 See id. at 71388, n.11 (citing Article IV, Section
4.14(a) of the FINRA Regulation By-Laws).
20 See id. at n.12. FINRA notes that the principles
outlined in the NAC’s Conflict of Interest and Bias
Policy are independence, impartiality, integrity,
accountability and transparency; and place upon
NAC adjudicators the responsibility for recognizing
and reporting actual and apparent conflicts of
interest and bias. See id.
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FINRA recognizes that there may,
depending on the facts and
circumstances, be overlap in part
between the new and existing grounds
to remove a NAC member. However,
FINRA states that, depending on the
facts and circumstances, the proposed
rule change may also provide an
additional basis for removal for a cause
affecting the best interests of the NAC
that would not fall within the scope of
the FINRA’s Board’s current removal
authority.21
III. Discussion and Commission
Findings
After careful review of the proposed
rule change, the Commission finds that
the proposed rule change is consistent
with the requirements of the Exchange
Act and the rules and regulations
thereunder that are applicable to a
national securities association.22 In
particular, the Commission finds that
the proposed rule change is consistent
with Section 15A(b)(4) of the Exchange
Act,23 which requires, among other
things, that the rules of a national
securities association, like FINRA,
assure the fair representation of its
members in the administration of its
affairs. Additionally, the Commission
finds that the proposed rule change is
also consistent with Section 15A(b)(6) of
the Exchange Act,24 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.
As a threshold matter, the
Commission observes that the provision
that is being added to the FINRA
Regulation By-Laws by this proposed
rule change mirrors a parallel provision
found in the FINRA By-Laws.25
Moreover, the Commission has
previously reviewed and approved a
proposal that conformed the then-NASD
Regulation By-Laws to the FINRA ByLaws, and has also previously reviewed
and approved the NAC committee and
its governance structure (which remains
the same under this proposal), finding
both proposals to be consistent with
Section 15A(b)(4) of the Exchange Act.26
21 See
id. at 71389.
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).
23 15 U.S.C. 78o–3(b)(4).
24 15 U.S.C. 78o–3(b)(6).
25 See Notice, 85 FR at 71388 (comparing Article
VII, Section 1(b) of the FINRA By-Laws with Article
V, Sec. 5.8 of the FINRA Regulation By-Laws).
26 See id. at n.17 (citing Exchange Act Release No.
56145 (July 26, 2007), 72 FR 42169 (August 1, 2007)
(the ‘‘NASD By-Laws Approval Order’’), as
22 In
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9111
We discuss below some of the pertinent
aspects of the Commission’s prior
findings as they apply, at least in part,
to the current proposed rule change.
As the Commission explained in
approving the FINRA By-Laws, Section
15A(b)(4) requires that the rules of a
national securities association, like
FINRA, assure the fair representation of
its members in, among other things, the
administration of its affairs.27 In
approving the FINRA By-Laws, the
Commission found, in part, that
FINRA’s members’ participation on
various committees provided for the fair
representation of members in the
administration of the affairs of a selfregulatory organization such as FINRA,
particularly with respect to
participation on committees relating to,
among other things, the disciplinary
process.28 More specifically, the
Commission observed that FINRA has
extensive member involvement in the
administration of its affairs through
representation on various subject matter
committees, including the NAC.29 In
connection with this proposal, FINRA
states that, similar to the FINRA ByLaws addressing the composition of its
Board, the FINRA Regulation By-Laws
addressing the composition of the NAC
provide for a diverse, majority nonindustry composition, and for the fair
representation of industry.30 The
Commission agrees with FINRA’s
statements and, moreover, observes that
the Commission found previously that
the NAC’s governance structure,
including the NAC’s composition as
well as the nomination and election
processes for NAC seats, align with
those of the FINRA Board and were
consistent with Section 15A(b)(4) of the
Act.31
Furthermore, in approving certain
amendments to the then-NASD
Regulation By-Laws, the Commission
found that because those amendments
conformed certain NASD Regulation ByLaws provisions to the relevant
amended by Exchange Act Release No. 56145A
(May 30, 2008), 73 FR 32377 (June 6, 2008) (Order
Approving File No. SR–NASD–2007–023)). These
orders approved FINRA’s By-Laws when the NASD
merged with the member regulation, enforcement
and arbitration operations of the New York Stock
Exchange (‘‘NYSE’’) to form FINRA. See also infra
notes 31–32.
27 See NASD By-Laws Approval Order, 72 FR at
42182 (explaining that this requirement helps to
assure that members have a stake in the governance
of the national securities association, which is
charged with self-regulatory responsibilities under
the Exchange Act).
28 See id. at 42185.
29 See id. See also supra note 7 and
accompanying text.
30 See supra note 15 and accompanying text.
31 See FINRA Regulation By-Laws Approval
Order, 73 FR at 68469–70.
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provisions in the FINRA By-Laws and
reflected the governance structure set
forth in the FINRA By-Laws those
amendments were consistent with the
Exchange Act.32 Similarly, this proposal
will also further conform the FINRA
Regulation By-Laws with the FINRA ByLaws and will also continue to reflect
the previously approved governance
structure of the NAC. As a result, the
Commission believes that this proposal
will continue to help assure the fair
representation of FINRA members in the
administration of FINRA’s affairs and,
therefore, is consistent with Section
15A(b)(4) of the Act.
The Commission further observes that
the NAC acts on behalf of the FINRA
Board in several important capacities,
including presiding over disciplinary
matters that have been appealed to or
called for review by the NAC and acting
on applications in statutory
disqualification and membership
proceeding.33 Given the NAC’s ability to
perform these actions and prepare
written decisions on behalf of the
FINRA Board, and that these decisions
become FINRA’s final action in the vast
majority of cases,34 the Commission
finds that applying the same grounds for
the removal of a NAC member as those
that apply for the removal of a governor
is consistent with the Act. The proposal
will strengthen the FINRA Board’s
oversight of the NAC and further
support the principles outlined in the
NAC’s Conflict of Interest and Bias
Policy, which include independence,
impartiality, integrity, and
accountability.35 In doing so, the
proposal will help protect investors and
further the public interest by expanding
the scope of the FINRA Board’s
authority to remove NAC members that,
in the Board’s view, may be biased or
have actual or apparent conflicts of
interest or otherwise impede the NAC’s
adjudicatory responsibilities.36
In sum, the Commission finds that the
proposal will continue to help assure
the fair representation of FINRA
members in the administration of
FINRA’s affairs. The Commission also
finds that this proposal will help protect
investors and further the public interest
by supporting fair and impartial
adjudicatory processes for, among other
things, FINRA’s disciplinary matters as
well as statutory disqualification and
membership proceedings.
32 See NASD By-Laws Approval Order, 72 FR at
42188.
33 See supra note 7 and accompanying text.
34 See Notice, 85 FR at 71389.
35 See id. at 71388, n.12. See also supra note 20
and accompanying text.
36 See id. at 71388 (citing Article IV, Section
4.14(a) of the FINRA Regulation By-Laws).
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IV. Conclusion
It is therefore ordered pursuant to
Section 19(b)(2) of the Exchange Act 37
that the proposal (SR–FINRA–2020–
037) is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.38
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021–02779 Filed 2–10–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–91068; File No. SR–
NYSEAMER–2021–06]
Self-Regulatory Organizations; NYSE
American LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Modify Rule 971.2NY
Regarding Its Complex Customer Best
Execution Auction
February 5, 2021.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934
(‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that on January
27, 2021, NYSE American LLC (‘‘NYSE
American’’ 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.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to modify
Rule 971.2NY regarding its Complex
Customer Best Execution (‘‘CUBE’’)
auction to provide optional all-or-none
functionality for larger-sized orders and
to make conforming changes to Rule
971.1NY to clarify existing functionality
of the Single-Leg AON CUBE
functionality. The proposed rule change
is available on the Exchange’s website at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
37 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
38 17
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of 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 the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to expand its
electronic crossing mechanism—the
CUBE Auction, to provide optional allor-none (‘‘AON’’) 4 functionality for ATP
Holders to execute larger-sized orders
(i.e., at least 500 contracts on the
smallest leg) in the Complex CUBE
Auction and to make conforming
changes to Rule 971.1NY to clarify
existing functionality of the Single-Leg
AON CUBE functionality.5
The proposed rule change would be
consistent with the recently approved
AON CUBE Order functionality for the
Single-Leg CUBE Auction.6 In this
regard, the Exchange seeks to expand
this functionality to the Complex CUBE
Auction, which functionality is also
consistent with similar priceimprovement mechanisms for largersized complex orders already available
on other options exchanges.7 As such,
4 An All-or-None Order or AON Order is a
‘‘Market or Limit Order that is to be executed on
the Exchange in its entirety or not at all.’’ See Rule
900.3NY(d)(4).
5 See proposed Commentary .04 to Rule 971.2NY;
proposed Commentary .05 to Rule 971.1NY.
Capitalized terms have the same meaning as the
defined terms in Rules 971.1NY and 971.2NY.
6 See Commentary .05 to Rule 971.1NY; see also
Securities Exchange Act Release No. 90584
(December 7, 2020), 85 FR 80196 (December 11,
2020) (SR–NYSEAmer–2020–60) (order approving
auction functionality for Single-Leg AON CUBE
Orders of at least 500 contracts). As proposed, AON
Complex CUBE Orders would be processed and
executed in the Complex CUBE Auction in a similar
manner as Single-Leg AON CUBE Orders are
processed and executed in the Single-Leg CUBE
Auction—the differences for Complex relating
primarily to the underlying differences between
simple and complex order processing and execution
(i.e., auction pricing and allocation).
7 See, e.g., Nasdaq ISE LLC (‘‘ISE’’), Options 3,
Section 11(e) (setting forth its Complex Solicited
Order Mechanism which allows an agency complex
order to execute in full against the solicited
complex order—both of which are designated as
AON—at the proposed execution net price so long
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Agencies
[Federal Register Volume 86, Number 27 (Thursday, February 11, 2021)]
[Notices]
[Pages 9110-9112]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-02779]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-91070; File No. SR-FINRA-2020-037]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Approving Proposed Rule Change To Amend the By-
Laws of FINRA Regulation, Inc. To Align the Grounds for Member Removal
From the NAC With an Existing Provision in the FINRA By-Laws
February 5, 2021.
I. Introduction
On October 22, 2020, 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 (the ``Act'' or ``Exchange Act'') \1\ and Rule
19b-4 thereunder,\2\ a proposed rule change to amend a provision in the
By-Laws of FINRA Regulation, Inc. (``FINRA Regulation''), FINRA's
regulatory subsidiary. The proposed rule change would further align the
grounds in the FINRA Regulation By-Laws for removal of a member from
the National Adjudicatory Council (``NAC'') with an existing provision
in the FINRA By-Laws for removal of a governor from the FINRA Board of
Governors (``FINRA Board'').\3\
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See infra Section II.
---------------------------------------------------------------------------
The proposed rule change was published for comment in the Federal
Register on November 9, 2020.\4\ The Commission received no comments on
the proposed rule change. This order approves the proposed rule change.
---------------------------------------------------------------------------
\4\ See Exchange Act Release No. 90324 (November 3, 2020), 85 FR
71387 (November 9, 2020) (File No. SR-FINRA-2020-037) (the
``Notice'').
---------------------------------------------------------------------------
II. Description of the Proposal
As described in the Notice, FINRA Regulation is the regulatory
subsidiary of FINRA and operates according to the Plan of Allocation
and Delegation of Functions by FINRA to Subsidiaries (the ``Plan'').\5\
The FINRA Regulation By-Laws authorize the NAC to function on behalf of
the FINRA Board in several capacities.\6\ For example, FINRA explains
that the NAC presides over disciplinary matters that have been appealed
to or called for review by the NAC and also acts on applications in
statutory disqualification and membership proceedings.\7\ In most
matters that the NAC considers, FINRA states that the NAC prepares
proposed written decisions that become final FINRA action if the FINRA
Board does not call for review of those decisions.\8\
---------------------------------------------------------------------------
\5\ See id. at 71388, n.4 (citing the Plan, Sec. II., FINRA
Regulation, Inc., https://www.finra.org/rules-guidance/rulebooks/corporate-organization/ii-finra-regulation-inc).
\6\ See id. (citing Article V, Sec. 5.1 of the FINRA Regulation
By-Laws).
\7\ See id. FINRA states that the NAC also exercises exemption
authority and acts in other proceedings as set forth in the FINRA
Rule 9000 Series (Code of Procedure). The FINRA Board may also
delegate other powers and duties to the NAC as the FINRA Board deems
appropriate and in a manner not inconsistent with the Plan. See id.
\8\ See id.
---------------------------------------------------------------------------
FINRA also states that it periodically reviews its and FINRA
Regulation's By-Laws to ensure adherence to effective governance
practices.\9\ Based on that review, FINRA explains that currently,
Article V, Section 5.8 of the FINRA Regulation By-Laws provides that,
``[a]ny or all of the members of the [NAC] may be removed from office
at any time for refusal, failure, neglect, or inability to discharge
the duties of such office by majority vote of the FINRA Board.'' \10\
By comparison, however, the FINRA By-Laws provide that a governor may
be removed for those grounds as well as ``for any cause affecting the
best interests of [FINRA] the sufficiency of which the Board shall be
the sole judge.'' \11\ As a result, FINRA proposes to amend the FINRA
Regulation By-Laws to add this ground for removal of a NAC member to
further align the bases for removal of a NAC member with the bases for
removal of a FINRA Board governor.\12\ Specifically, the proposed rule
change would amend the FINRA Regulation By-Laws to permit a NAC member
to be removed by a majority vote of the FINRA Board ``for any cause
affecting the best interests of the [NAC] the sufficiency of which the
FINRA Board shall be the sole judge.'' \13\
---------------------------------------------------------------------------
\9\ See id.
\10\ See id. As FINRA explains, the FINRA Regulation By-Laws
were amended in 2008 to, among other things, designate the FINRA
Board as the body authorized to oversee the NAC and empowered to
remove NAC members for the grounds mentioned above. See id. (citing
Exchange Act Release No. 58909 (November 6, 2008), 73 FR 68467
(November 18, 2008) (Order Approving File No. SR-FINRA-2008-046)
(the ``FINRA Regulation By-Laws Approval Order'').
\11\ See id. Compare Article VII, Section 1(b) of the FINRA By-
Laws, with Article V, Sec. 5.8 of the FINRA Regulation By-Laws.
\12\ See Notice, 85 FR at 71388.
\13\ See id.
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FINRA further explains that the removal of a NAC member would
continue to require a majority vote of the FINRA Board, while a vote to
remove a FINRA Board governor requires a two-thirds vote.\14\ In
[[Page 9111]]
discussing this difference between voting thresholds for removal, FINRA
states that the higher voting standard for the removal of a governor
reflects the historical standard that existed at the National
Association of Securities Dealers (``NASD'') prior to the formation of
FINRA, and that it provides an additional safeguard at the FINRA Board
level ``to ensure a diverse, majority non-industry composition, and
fair representation of the industry in governance matters.'' \15\
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\14\ See id. As FINRA notes, both FINRA and FINRA Regulation are
corporations organized under Delaware law. The Delaware General
Corporation Law provides that, in general, directors may be removed
by a majority vote of the shares then entitled to vote at an
election of directors. See Del. Code Ann. Tit. 8, Sec. 141(k).
FINRA states that it has adopted a removal threshold for NAC members
that is consistent with the Delaware General Corporation Law,
although the NAC is not subject to this standard. See Notice, 85 FR
at 71388, n.9.
\15\ Notice, 85 FR at 71388. FINRA also notes that the provision
of the FINRA Regulation By-Laws addressing the composition of the
NAC also provides for a diverse, majority non-industry composition,
and for the fair representation of the industry. See id. at n.10
(citing Article V, Section 5.2(a) of the FINRA Regulation By-Laws
and Exchange Act Release No. 78094 (June 17, 2016), 81 FR 40932,
40934-35 (June 23, 2016)).
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FINRA also states that, given the NAC's adjudicatory role, the best
interests of the NAC are more targeted than the best interests of
FINRA.\16\ More specifically, FINRA explains that the best interests of
the NAC are reflected in conduct and attributes that ensure that the
NAC remains an unbiased and competent adjudicatory body that is free of
conflicts of interest, that its members conduct themselves with
integrity, and that its decisions are rendered fairly and consistently
with the law and rules that govern FINRA members and their associated
persons.\17\ FINRA also states that the FINRA Board's decision to
remove a NAC member is a facts and circumstances determination.\18\ In
considering whether to remove a NAC member for cause affecting the best
interests of the NAC, FINRA explains that its Board may consider, among
other things, the NAC member's adherence to general standards
concerning actual and apparent adjudicator conflicts of interest and
bias,\19\ and to the NAC's Conflict of Interest and Bias Policy, which
sets forth broad-based principles of behavior that are expected from
NAC members.\20\ FINRA recognizes that there may, depending on the
facts and circumstances, be overlap in part between the new and
existing grounds to remove a NAC member. However, FINRA states that,
depending on the facts and circumstances, the proposed rule change may
also provide an additional basis for removal for a cause affecting the
best interests of the NAC that would not fall within the scope of the
FINRA's Board's current removal authority.\21\
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\16\ See id.
\17\ See id.
\18\ See id. at 71388-89.
\19\ See id. at 71388, n.11 (citing Article IV, Section 4.14(a)
of the FINRA Regulation By-Laws).
\20\ See id. at n.12. FINRA notes that the principles outlined
in the NAC's Conflict of Interest and Bias Policy are independence,
impartiality, integrity, accountability and transparency; and place
upon NAC adjudicators the responsibility for recognizing and
reporting actual and apparent conflicts of interest and bias. See
id.
\21\ See id. at 71389.
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III. Discussion and Commission Findings
After careful review of the proposed rule change, the Commission
finds that the proposed rule change is consistent with the requirements
of the Exchange Act and the rules and regulations thereunder that are
applicable to a national securities association.\22\ In particular, the
Commission finds that the proposed rule change is consistent with
Section 15A(b)(4) of the Exchange Act,\23\ which requires, among other
things, that the rules of a national securities association, like
FINRA, assure the fair representation of its members in the
administration of its affairs. Additionally, the Commission finds that
the proposed rule change is also consistent with Section 15A(b)(6) of
the Exchange Act,\24\ 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.
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\22\ 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).
\23\ 15 U.S.C. 78o-3(b)(4).
\24\ 15 U.S.C. 78o-3(b)(6).
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As a threshold matter, the Commission observes that the provision
that is being added to the FINRA Regulation By-Laws by this proposed
rule change mirrors a parallel provision found in the FINRA By-
Laws.\25\ Moreover, the Commission has previously reviewed and approved
a proposal that conformed the then-NASD Regulation By-Laws to the FINRA
By-Laws, and has also previously reviewed and approved the NAC
committee and its governance structure (which remains the same under
this proposal), finding both proposals to be consistent with Section
15A(b)(4) of the Exchange Act.\26\ We discuss below some of the
pertinent aspects of the Commission's prior findings as they apply, at
least in part, to the current proposed rule change.
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\25\ See Notice, 85 FR at 71388 (comparing Article VII, Section
1(b) of the FINRA By-Laws with Article V, Sec. 5.8 of the FINRA
Regulation By-Laws).
\26\ See id. at n.17 (citing Exchange Act Release No. 56145
(July 26, 2007), 72 FR 42169 (August 1, 2007) (the ``NASD By-Laws
Approval Order''), as amended by Exchange Act Release No. 56145A
(May 30, 2008), 73 FR 32377 (June 6, 2008) (Order Approving File No.
SR-NASD-2007-023)). These orders approved FINRA's By-Laws when the
NASD merged with the member regulation, enforcement and arbitration
operations of the New York Stock Exchange (``NYSE'') to form FINRA.
See also infra notes 31-32.
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As the Commission explained in approving the FINRA By-Laws, Section
15A(b)(4) requires that the rules of a national securities association,
like FINRA, assure the fair representation of its members in, among
other things, the administration of its affairs.\27\ In approving the
FINRA By-Laws, the Commission found, in part, that FINRA's members'
participation on various committees provided for the fair
representation of members in the administration of the affairs of a
self-regulatory organization such as FINRA, particularly with respect
to participation on committees relating to, among other things, the
disciplinary process.\28\ More specifically, the Commission observed
that FINRA has extensive member involvement in the administration of
its affairs through representation on various subject matter
committees, including the NAC.\29\ In connection with this proposal,
FINRA states that, similar to the FINRA By-Laws addressing the
composition of its Board, the FINRA Regulation By-Laws addressing the
composition of the NAC provide for a diverse, majority non-industry
composition, and for the fair representation of industry.\30\ The
Commission agrees with FINRA's statements and, moreover, observes that
the Commission found previously that the NAC's governance structure,
including the NAC's composition as well as the nomination and election
processes for NAC seats, align with those of the FINRA Board and were
consistent with Section 15A(b)(4) of the Act.\31\
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\27\ See NASD By-Laws Approval Order, 72 FR at 42182 (explaining
that this requirement helps to assure that members have a stake in
the governance of the national securities association, which is
charged with self-regulatory responsibilities under the Exchange
Act).
\28\ See id. at 42185.
\29\ See id. See also supra note 7 and accompanying text.
\30\ See supra note 15 and accompanying text.
\31\ See FINRA Regulation By-Laws Approval Order, 73 FR at
68469-70.
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Furthermore, in approving certain amendments to the then-NASD
Regulation By-Laws, the Commission found that because those amendments
conformed certain NASD Regulation By-Laws provisions to the relevant
[[Page 9112]]
provisions in the FINRA By-Laws and reflected the governance structure
set forth in the FINRA By-Laws those amendments were consistent with
the Exchange Act.\32\ Similarly, this proposal will also further
conform the FINRA Regulation By-Laws with the FINRA By-Laws and will
also continue to reflect the previously approved governance structure
of the NAC. As a result, the Commission believes that this proposal
will continue to help assure the fair representation of FINRA members
in the administration of FINRA's affairs and, therefore, is consistent
with Section 15A(b)(4) of the Act.
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\32\ See NASD By-Laws Approval Order, 72 FR at 42188.
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The Commission further observes that the NAC acts on behalf of the
FINRA Board in several important capacities, including presiding over
disciplinary matters that have been appealed to or called for review by
the NAC and acting on applications in statutory disqualification and
membership proceeding.\33\ Given the NAC's ability to perform these
actions and prepare written decisions on behalf of the FINRA Board, and
that these decisions become FINRA's final action in the vast majority
of cases,\34\ the Commission finds that applying the same grounds for
the removal of a NAC member as those that apply for the removal of a
governor is consistent with the Act. The proposal will strengthen the
FINRA Board's oversight of the NAC and further support the principles
outlined in the NAC's Conflict of Interest and Bias Policy, which
include independence, impartiality, integrity, and accountability.\35\
In doing so, the proposal will help protect investors and further the
public interest by expanding the scope of the FINRA Board's authority
to remove NAC members that, in the Board's view, may be biased or have
actual or apparent conflicts of interest or otherwise impede the NAC's
adjudicatory responsibilities.\36\
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\33\ See supra note 7 and accompanying text.
\34\ See Notice, 85 FR at 71389.
\35\ See id. at 71388, n.12. See also supra note 20 and
accompanying text.
\36\ See id. at 71388 (citing Article IV, Section 4.14(a) of the
FINRA Regulation By-Laws).
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In sum, the Commission finds that the proposal will continue to
help assure the fair representation of FINRA members in the
administration of FINRA's affairs. The Commission also finds that this
proposal will help protect investors and further the public interest by
supporting fair and impartial adjudicatory processes for, among other
things, FINRA's disciplinary matters as well as statutory
disqualification and membership proceedings.
IV. Conclusion
It is therefore ordered pursuant to Section 19(b)(2) of the
Exchange Act \37\ that the proposal (SR-FINRA-2020-037) is approved.
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\37\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\38\
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\38\ 17 CFR 200.30-3(a)(12).
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J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021-02779 Filed 2-10-21; 8:45 am]
BILLING CODE 8011-01-P