Timothy Githens Comment On Regulatory Notice 25-05
Thank you for the opportunity to comment on Regulatory Notice 25-05. While I support efforts to streamline oversight, I oppose the proposed consolidation of Rules 3270 and 3280 in their current form.
The definition of "investment-related activities" is overly broad and risks encompassing low-risk or personal activities that do not warrant regulatory scrutiny. This may overwhelm firms with unnecessary reporting while distracting from truly material conflicts.