Fredrick Scuteri Comment On Regulatory Notice 25-04
Fredrick Scuteri
CRD#[REDACTED]
I am writing to respectfully request your attention to an issue I have encountered regarding the process for obtaining a waiver for individuals like myself who have held multiple FINRA licenses in the past but whose registrations have expired due to factors outside of their control.
I have held several FINRA licenses dating back to 1998 (please refer to the attached report for details). In 2013, I transitioned from the sell side to the buy side, accepting a position at a FINRA-registered investment manager. Although I had the relevant experience, I was told by the compliance officer that I was ineligible to be registered with the firm because my role was in operations/treasury, which they deemed unrelated to the job functions requiring registration. As a result, my licenses expired in late 2015.
Fast forward to 2021, when I returned to the sell side at a member broker-dealer as its Chief Operating Officer. At that time, the compliance officer submitted a formal request for a waiver to reinstate my Series 7, 66, 55,9 & 10 licenses. However, I was informed that FINRA allegedly declined the waiver request with no specific reason given.
Now, at 52 years old, with 30 years of experience—almost all of it within registered firms—I am left in a difficult position: none of my previous registrations are active, and I find myself unable to utilize the full scope of my professional experience because of regulatory hurdles. I believe that this situation is a clear example of how the waiver process could be more accommodating to experienced professionals like myself who are unable to retake exams that we passed decades ago.
I understand the importance of regulatory requirements, but I also believe that individuals who have built long careers in the industry should not be penalized for circumstances that are beyond their control. I am respectfully requesting that FINRA consider revising the waiver process to make it more accessible to professionals with a proven track record, allowing them to continue contributing to the industry without the need to re-take exams that may no longer reflect their qualifications or expertise.
Thank you for your time and consideration. I would be happy to provide any further details or documentation regarding my case. I look forward to your response and hope we can work together to address this concern in a constructive manner.
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Fredrick Scuteri Comment On Regulatory Notice 25-04
I am writing to respectfully request your attention to an issue I have encountered regarding the process for obtaining a waiver for individuals like myself who have held multiple FINRA licenses in the past but whose registrations have expired due to factors outside of their control.
I have held several FINRA licenses dating back to 1998 (please refer to the attached report for details). In 2013, I transitioned from the sell side to the buy side, accepting a position at a FINRA-registered investment manager. Although I had the relevant experience, I was told by the compliance officer that I was ineligible to be registered with the firm because my role was in operations/treasury, which they deemed unrelated to the job functions requiring registration. As a result, my licenses expired in late 2015.
Fast forward to 2021, when I returned to the sell side at a member broker-dealer as its Chief Operating Officer. At that time, the compliance officer submitted a formal request for a waiver to reinstate my Series 7, 66, 55,9 & 10 licenses. However, I was informed that FINRA allegedly declined the waiver request with no specific reason given.
Now, at 52 years old, with 30 years of experience—almost all of it within registered firms—I am left in a difficult position: none of my previous registrations are active, and I find myself unable to utilize the full scope of my professional experience because of regulatory hurdles. I believe that this situation is a clear example of how the waiver process could be more accommodating to experienced professionals like myself who are unable to retake exams that we passed decades ago.
I understand the importance of regulatory requirements, but I also believe that individuals who have built long careers in the industry should not be penalized for circumstances that are beyond their control. I am respectfully requesting that FINRA consider revising the waiver process to make it more accessible to professionals with a proven track record, allowing them to continue contributing to the industry without the need to re-take exams that may no longer reflect their qualifications or expertise.
Thank you for your time and consideration. I would be happy to provide any further details or documentation regarding my case. I look forward to your response and hope we can work together to address this concern in a constructive manner.