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Michael Garawski

Michael Garawski is Senior Vice President and Director, Appellate Group, in FINRA’s Office of General Counsel (OGC). Mr. Garawski manages the program that advises FINRA’s National Adjudicatory Council and that represents FINRA in appeals that challenge FINRA’s regulatory actions before the SEC.  

Robert Cruz Comment On Regulatory Notice 25-07

E.1. The phrase business as such under Exchange Act Rule 17a-4(b)(4) is not defined.34 What questions, concerns or challenges, if any, does this raise with respect to ensuring compliance with the recordkeeping requirements? Are there categories of records that are especially costly or difficult to capture or retain, and which may provide no appreciable regulatory benefit? <EA1: Ambiguity of the rule has nothing to do with the degree of difficulty to capture and retain specific types of records.