Our comment letter focuses on the following:
- Request for further clarification of the proposed rule and additional guidance
- Concern with verification and reliance on information collected by member firms
- Seeks further guidance regarding information provided to the trusted contact person
- Concern with language related to changes in status for the trusted contact person and requests further guidance from FINRA
- Requests inclusion of additional language specifically excluding accounts where there is a designated guardianship, custodian or power of attorney
- Seeks additional protections for qualified persons at member firms
- Seeks further clarification on issues related to the temporary hold on disbursement of funds or securities
- Requests coordination and harmonization with State and Federal laws
You can find BDA’s final letter here and FINRA’s proposed rules here.
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