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Dear FINRA Regulatory Policy Committee,
I submit this comment in my capacity as an attorney who represents consumers, frequently elderly investors, in arbitration matters before FINRA. My practice includes representing victims of elder financial exploitation, fraud, and unauthorized account activity. In that role, I routinely observe how broker-dealer policies and discretionary enforcement decisions directly impact vulnerable seniors after irreversible losses have already occurred.
FINRA is reminding firms of upcoming updates to its equity trade reporting guidance in connection with enhancements to the FINRA equity trade reporting facilities to support reporting of fractional share quantities. Under the updated guidance, members engaged in fractional share trading will be required to report fractional share quantities up to six digits after the decimal. FINRA is also providing additional guidance for fractional share reporting in circumstances involving fractional amounts smaller than six decimals.
