Membership Application Proceedings

SIFMA provides comments to the Financial Industry Regulatory Authority (FINRA) regarding a proposal, FINRA Regulatory Notice 10-01, to transfer the existing National Association of Securities Dealers (NASD) membership rules into the Consolidated FINRA Rulebook as the FINRA Rule 1100 Series, with significant substantive changes based, in part, on existing NYSE membership rules. SIFMA agrees in principle with FINRA’s stated goals of streamlining the standards of review for New Membership Applications (NMAs) and Continuing Membership Applications (CMAs). SIFMA presents its concerns about the business impact of the new advance notification requirements found in proposed FINRA Rule 1170. SIFMA also is troubled by the apparent breadth of two new evaluation standards for FINRA NMAs and CMAs.