Comment Letters, Testimony & Statements for the Record


Association Health Plans 2/26/18

DOL Fiduciary Rule 4/18/17

Delay of DOL Fiduciary Rule 3/17/17

City-Run Retirement 9/29/16

State-Run Retirement Proposal 1/19/16

Supplemental Comment Letter On Fiduciary Rule 9/24/15


Initial Comment Letter on Fiduciary Rule 7/21/15Regulation Best Interest 8/7/18

Draft FY 2018-2022 Strategic Plan 7/25/18

Shortened Settlement Cycle 12/2/16

SR FINRA 2016-039 Financial Exploitation of Specified Adults 11/28/16

SR FINRA 2016-033 Broadening Chairperson Eligibility in Arbitration 9/27/16

SR-FINRA 2016-030 Proposed Rule Change to Amend FINRA Rule 12504 of the Code of Arbitration Procedure for Customer Disputes and FINRA Rule 13504 of the Code of Arbitration Procedure for Industry Disputes 9/7/16

SR-FINRA-2016-029 Proposed Rule relating to use of the Dispute Resolution Party Portal in Arbitration and Mediation 9/7/16

Adviser Business Continuity and Transition Plans 9/6/16

SR-FINRA-2016-022: Proposed Rule Change Regrading Arbitration of Customer Disputes 8/4/16

Incentive Based Compensation Arrangements 7/22/16

Consolidated Audit Trail 7/18/16

SR-MSRB-2016-07 Proposed Rule Change Regarding Close-Out Procedures for Municipal Securities 6/22/16

SR-FINRA-2016-015 Proposed Rule Change to Provide that Absent Specification to the Contrary in an Award, When Arbitrators Order Opposing Parties to Pay Each Other Damages, the Monetary Awards Shall Offset 6/13/2016

SR-FINRA-2016-014 Proposed Rule Change Relating to National Adjudicatory Council Composition, Member Terms and Election Procedures 5/19/2016

SR-FINRA 2015-056 “Pay to Play” Rule 4/27/16

SR-MSRB-2016-04 Proposal to Shorten The Settlement Cycle For Municipal Securities 4/8/16

SR-FINRA-2016-004: FINRA Coordination with the MSRB 3/11/16

Mutual Fund Liquidity 2/4/16

“Pay to Play” Rule 1/20/16

SR-FINRA-2015-057: Educational Communication Related to Recruitment Practices and Account Transfers 1/20/16

SR-FINRA-2015-022: BrokerCheck Hyperlinks Proposal 8/3/15

SR-FINRA-2015-015: Web-Based Delivery of Continuing Education Proposal 7/8/15

SR-MSRB-2015-03: Amendment to Municipal Advisor Rule


FINRA Report on Technology Based Innovations for Regulatory Compliance in the Securities Industry 11/30/2018

Regulatory Notice 18-23 | FINRA Requests Comment on a Proposal Regarding the Rules Governing the New and Continuing Membership Application Process (Notice) 10/05/2018

Regulatory Notice 18-16 | FINRA Requests Comment on FINRA Rule Amendments Relating to High-Risk Brokers and the Firms That Employ Them (Notice)

Regulatory Notice 18-13 | FINRA Requests Comment on Proposed Amendments to the Quantitative Suitability Obligation Under FINRA Rule 2111 (Notice)

Regulatory Notice 18-08 | FINRA Requests Comment on Proposed New Rule Governing Outside Business Activities and Private Securities Transactions (Notice) 04/27/18

Regulatory Notice 18-06 |FINRA Requests Comment on Proposed Amendments to its Membership Application Program to Incentivize Payment of Arbitration Awards (Notice) 04/09/18

Regulatory Notice 17-42|Expungement of Customer Dispute Information (Notice) 02/05/18

Regulatory Notice 17-38; Request for Comment on Proposal to Amend Rule 3110 (Supervision) to Provide Firms the Option to Conduct Remote Office Inspection of Offices and Locations That Meet Specified Criteria (Notice) 01/12/18

Regulatory Notice 17-34; Request for Comment on the Efficacy of Allowing Compensated Non-Attorneys to Represent Parties in Arbitration (Notice) 12/18/17

Regulatory Notice 17-33; Amendments to the Code of Arbitration Procedure for Customer Disputes to Expand the Options Available to Customers if a Firm or Associated Person Is or Becomes Inactive (Notice) 12/18/17

Special Notice: Comment on Potential Enhancements to Certain Engagement Programs 6/19/17

SR-FINRA-2017-007: Proposed Consolidated Qualification, Registration and Examination Requirements 5/1/17

Regulatory Notice 17-06: Retrospective Rule Review: Communications with the Public 3/17/17

Regulatory Notice 16-29: Proposed Amendments to Gifts, Gratuities and Non-Cash Compensation Rules 9/23/16

Regulatory Notice 16-09: Shortened Settlement Cycle 4/4/16

Regulatory Notice 15-37: Elder Abuse Proposal 12/4/15

Regulatory Notice 15-22: Discretionary Accounts and Trading Proposal 8/17/15

Regulatory Notice 15-20: Qualifying Exam Concept Release 7/27/15

Regulatory Notice 15-19: Recruitment Compensation Proposal 7/13/15

Regulatory Notice 15-16: Retrospective Rule Review: Communications with the Public 7/2/15Regulatory Notice 2017-22 MSRB Seeks Input on Compliance Support 2/9/18


MSRB Advertising Rule. FSI supported the Proposed Rule both for its content and because it serves to further harmonize rules applicable to our members across regulatory jurisdictions 3/24/17

Regulatory Notice 2016-024 Continuing Education for Municipal Advisors 11/14/16

Regulatory Notice 2016-025 Strategic Priorities 11/11/16

Regulatory Notice 2016-023 Minimum Denominations 10/11/16

Regulatory Notice 15-16: Proposed Pricing Disclosure Rule 12/11/15

Regulatory Notice 15-22: Proposal to Shorten The Settlement Cycle For Municipal Securities 12/10/15

U.S. Department of Treasury

Registered Investment Adviser Anti-Money Laundering Proposal (FINCEN) 11/2/15

MyRA Proposal 10/23/15


Proposed Amendment to the NASAA Statement of Public Policy Regarding Real Estate Investment Trusts 9/12/16

Elder Abuse Prevention Model Legislation 10/30/15



Comments Regarding Proposed Changes to Title 48 of the Nebraska Administrative Code 8/10/16

New Hampshire

Senior-Specific Certifications and Professional Designations 12/8/16

New York

Cybersecurity Requirements for Financial Services Companies 1/27/17


Rules of the Oregon State Retirement Savings Plan 2/22/17


Comment Letter on Securities Regulation Omnibus Amendments 8/1/16


Senior Designations 5/20/15


Amendments on Communications and Balance Sheets 7/20/15


Securities Regulatory Proposal 3/29/16


Small Business Retirement Market Place Proposal – Department of Commerce 3/17/16

Small Business Retirement Market Place Proposal – Department of Financial Services 2/29/16



FSI Submits Letter Supporting the Small Business Audit Correction Act of 2018


FSI Submits Letter Supporting the Small Business Audit Correction Act of 2018


FSI President & CEO Dale Brown and W. Mark Smith, Partner, Sutherland Asbill & Brennan LLP before the Employee Benefits Security Administration Department of Labor on the Proposed DOL Fiduciary Rule 8/12/15

FSI Member Dean Harman, Founder & Managing Director of Harman Wealth Strategies before the U.S. House Committee on Education & the Workforce Subcommittee on Health, Employment, Labor and Pensions 6/17/15

Statements for the Record

FSI President & CEO Dale Brown before the U.S. House Education and Workforce Committee On “Examining the Policies and Priorities of the U.S. Department of Labor” 3/15/16