Dear Mr. Cook:
The undersigned entities submit this letter to express their concerns with the outdated manner in which margin requirements for pattern day traders with accounts below $25,000 are calculated and respectfully urge FINRA to modernize aspects of FINRA Rule 4210 to account for market developments. As you know, Rule 4210 was put in place in 2001, and the section of the rule related to the treatment of margin for pattern day trader accounts has not kept pace with technological advancements – including those that have expanded investor access to the markets. We are concerned that many first-time investors and investors with modest account balances are often being confusingly shut out from the markets if they are inadvertently deemed a pattern day trader under Rule 4210.