STA believes that a meaningful number of market participants anticipate the Commission granting an extension on the existing “no-action” relief. Therefore, a decision to allow the relief to expire in July 2020 risks to be highly disruptive if firms are not provided adequate time to adjust to the regulatory regime. Expiration would have a particular impact on those broker-dealers who may decide to register their research departments as investment advisers to accommodate cash payments.

Read full letter here