The Security Traders Association (“STA”) appreciates the opportunity to provide comments in
response to the aforementioned Request for Comment (the “Request”) published by FINRA. STA
is an organization comprised of individuals who are involved in the trading of financial securities
in the U.S and Canada. Our members are employed at retail brokerage firms, agency only broker
dealers, asset owners and managers, market makers, liquidity providers and exchanges.
The Request reminds FINRA members of their current regulatory obligations, including the
application of Regulation Best Interest (Reg BI) when broker-dealers and their associated
persons make securities recommendations, and recommendations of investment strategies
involving securities, to retail customers, and seeks comment on: (1) effective practices that
members have developed for complex products and options, particularly when retail investors
are involved; and (2) whether the current regulatory framework, which was adopted at a time
when the majority of individuals accessed financial products through financial professionals
rather than through self-directed platforms, is appropriately tailored to address current
concerns raised by complex products and options.
Read the comment letter here.