Today, the BDA submitted a comment letter to FINRA in response to its request for comment on a proposed rule to establish the Comprehensive Automated Risk Data System (CARDS). You can find the BDA’s final letter here.
CARDS would require broker-dealers to submit to FINRA comprehensive customer account and transaction data for each of its customer accounts on a monthly basis.
BDA’s letter states that FINRA’s rule proposal does not provide firms with sufficient information to estimate the significant initial and ongoing cost burdens of CARDS. In addition, the letter highlights the proposal’s insufficient attention to emerging cyber security threats and FINRA’s untested ability to protect the highly valuable, private customer account information it intends to centralize in the CARDS database.
