Insights

Nov
22
To Be Heard

By Peggy E. Chait and Howard Spindel


For those of you that are old enough to remember the slogan, “when EF Hutton talks, people listen”, and the powerful effect the ad had on the general public, we can now attest that when the Wall Street community gathers in unity and speaks out, the regulators eventually listen.


We at Integrated Solutions are proud to be a member of the community that has been speaking up for a soon to be effective change in FINRA’s rule 1210. See FINRA Regulatory Notice 21-41. As a leading provider of financial accounting and compliance services to the financial services industry, we have written comment letters to FINRA on several occasions (June 30, 2020, and July 14, 2021) espousing the virtue of expanding the timeframe in which securities licensing remains active to allow more flexibility for qualified individuals to remain in the industry without fear of losing their hard-earned licensure. We pointed out that many professions allowed the continuance of an individual’s licensing (i.e., medical, accounting, law) for life, upon the condition of meeting the requirements for Continuing Education.


Although we did not meet the goal of lifetime licensure even for persons not associated with a FINRA member, we were able to help move the needle to a more reasonable requirement. We appreciate and thank FINRA for amending the rule by finally recognizing that with a reasonable schedule of Continuing Education training, a registered individual could remain knowledgeable of industry rules and requirements. We believe that this change will benefit the financial services industry by allowing competent, experienced individuals to address their personal needs while also allowing them to return and contribute to their chosen field.


On the other hand, to satisfy the intensifying and continuing need for Continuing Education, FINRA has also amended Rule 1240, which will now require annual Regulatory Element sessions instead of triennial ones. The burden of doing so will be minimized because of the representative’s ability to complete the session at a location convenient to them, such as their home or office, rather than having to visit a test center.


We regret that FINRA did not yet listen to other suggestions we made. We would like for persons interested in taking qualifying examinations to be able to maintain their qualifications through the Continuing Education program, allowing them to join FINRA members and qualify instantaneously to do so. Obvious candidates for such a program would be:



  • Regulatory personnel

  • Independent auditor personnel

  • College and university students and professors

  • Attorneys


We cannot understand why an interested person cannot qualify by examination without having a current or previous affiliation with a FINRA member. We also would like to see that professionals who deal with FINRA members in any capacity become better educated and trained than they currently are.


We at Integrated Solutions are here to advocate for our fellow professionals and to help support and guide our clients with expertise and understanding. Please feel free to reach out to us for all of your compliance and financial services needs. When you talk, we listen.


Peggy Chait pchait@integrated.solutions 212-897-1698


Howard Spindel hspindel@integrated.solutions 561-420-0842


NEW YORK

42 Broadway, Suite 12-129

New York, NY 10004

Telephone: 212-509-7800

FLORIDA

7000 W Palmetto Park Rd., Suite 503

Boca Raton, FL 33433

Telephone: 561-453-3800

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*SOC 1 Type 2 certification only covers:

Fund Accounting, Administration and Investor Services.

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