The proposal is a step in the right direction but could be simplified to make it easier to read in conjunction with other rules. I think it needs more explanation as to the historical reasons behind distinguishing between registered persons and associated persons, and clarification in other rules like 3210 where they are referred implicitly by the rule saying "No person associated with a member" instead of "Associated Person", which is how the text appears in 1011. The proposal seems to blur the actual lines between the two. In other words, it would make more sense if FINRA explained the risks posed by APs as compared to registered persons why there is a distinction. Many jobs at modern broker dealers don't have much to do with the reasons we have 3270 and 3280; and I think those are still being swept in a bit too much. The decision tree on whether to report is also too complicated.
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Molly Dresden Comment On Regulatory Notice 25-05
The proposal is a step in the right direction but could be simplified to make it easier to read in conjunction with other rules. I think it needs more explanation as to the historical reasons behind distinguishing between registered persons and associated persons, and clarification in other rules like 3210 where they are referred implicitly by the rule saying "No person associated with a member" instead of "Associated Person", which is how the text appears in 1011. The proposal seems to blur the actual lines between the two. In other words, it would make more sense if FINRA explained the risks posed by APs as compared to registered persons why there is a distinction. Many jobs at modern broker dealers don't have much to do with the reasons we have 3270 and 3280; and I think those are still being swept in a bit too much. The decision tree on whether to report is also too complicated.