Comment Letter Addresses Significant Concerns, Provides Constructive Recommendations
The Financial Services Institute (FSI) today submitted a comment letter to FINRA on its Comprehensive Automated Risk Data System (CARDS).
“We are deeply committed to FINRA’s investor protection goals and to continuing our constructive engagement on important regulatory initiatives such as CARDS,” said FSI President & CEO Dale Brown. “We also have significant concerns with the current version of CARDS and address those concerns, along with recommendations for improvement, in great detail in our comment letter.”
In September, FSI announced its Board-level CARDS Task Force. Leading the Task Force is LPL Financial President Robert Moore. Amy Webber, President of Cambridge Investment Research and Steve Chipman, CEO of Foothill Securities, represent the FSI Board of Directors on the Task Force, with members of the FSI Compliance Council and the FSI Operations & Technology Council forming the rest of the group.
“Regardless of the issue, FSI consistently strives to engage constructively with regulators and elected officials, and that is certainly the case with CARDS,” said Robert Moore. “Our Board and Task Force have worked diligently on this process since January because we support the investor protection goals of FINRA and the CARDS proposal, and we are all equally committed to investor protection.”
“Firms have real-life experience with leveraging technology to enhance their own rigorous supervision and compliance efforts,” said Amy Webber. “Our Task Force has presented FINRA with highly considered recommendations and the information it needs to ensure CARDS can both protect investors and the industry they depend on.”
“FINRA has ambitious goals for CARDS, and to reach those goals there are going to be costs,” said Steve Chipman. “Our Task Force, through our thoughtful and thorough comment letter, describes the challenges that small firms in particular would face – and provides critical recommendations that would balance these costs with the possible benefits.”
CLICK HERE to read the comment letter and executive summary.
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