Tags: Continuing Education

Trading Views Podcast

We welcomed business thought leader Eleanor Beaton in Episode 3, who gave sound advice to those who want to start their own business and how to bring an entrepreneurial mindset to your current role.

It’s a centuries-old proverb: Necessity is the mother of invention . With 90% of our industry still in a work-from-home state, individuals have had to adjust and create novel solutions to fit their unique situations.

For many of us who spent entire careers in a structured corporate culture, we have discovered skills that are typically associated with entrepreneurs.

In this episode, we will be speaking with Eleanor Beaton, an advisor and coach to entrepreneurs. As a successful entrepreneur herself, Eleanor shares her thoughts and observations of those entrepreneurs she has advised over the years.

Our goal with today’s podcast is that, Regardless of whether you’re trying to get creative in thriving with isolation or are thinking of starting your business, understanding the skillsets and disciplines of successful entrepreneurs can help in your career development.

Talking Points – December 2019

Talking Points

Who We Are The Security Traders Association, “STA” 1 is comprised of 24 affiliate organizations covering the US and Canada. The STA national board of governors is comprised of past presidents and industry specific leaders. Our membership represents INDIVIDUALS from varying business models – buy-side, sell-side, hedge funds, exchange traders and market makers- dealing in equity and derivative trading.

Issues

  • SEC Transaction Fee Pilot for NMS Securities
  • Order Protection Rule
  • FINRA Regulatory Notice 18-26; Continuing Education Program
  • Listed Options Working Group, “LOMSWG”
  • Thinly Traded Securities – UTP

Specific Comments

SEC Transaction Fee Pilot for NMS Securities

  • *STA believes that the impact access fees have on our market structure has evolved since they were originally allowed and then capped. We therefore support a study that includes a pilot.

Order Protection Rule

  • *In 2008 STA wrote “STA is of the opinion that a marketplace without this order protection rule will be superior to enforcing the current OPR. While this opinion would appear “anti-investor”, it is not. While the OPR was well intended, its many complex exemptions complicate compliance and dilute its effectiveness.”
  • *As STA reviews its existing opinion, we will take into consideration OPR’s impact on solutions which seek to improve the trading of Thinly Traded securities and its need in the trading of liquid securities.

FINRA Regulatory Notice 18-26; Continuing Education Program Maintaining Qualification Status Post-Termination

  • *STA believes that FINRA has taken meaningful steps to address what we view as two (2) unreasonable barriers to re-enter the financial services industry exists for individuals with a prolonged absence. Specifically, effective October 8, 2018, FINRA instituted the Securities Industry Essential (“SIE”) Exam. STA believes that the next contributing factor which needs to be addressed is continuing education requirements for individuals away from the industry for a prolonged period of time.

Listed Options Working Group, “LOMSWG”

  • *LOMSWG was formed to address issues regarding the current state of the U.S. options market structure. Formed in Q3’2018, LOMSWG is comprised of representatives from the options Exchange parent organizations; Options Clearing Corporation and the Options Committees of SIFMA and STA.
  • *Since exchanges must ensure that any collective activity on their part conforms to applicable laws, in particular— because the exchanges are competitors—participation by SEC staff is provided.
  • *Among the issues which LOMSWG is currently addressing include: Smarter Strikes ; Exchange Give Ups and Obvious Error RFP Process.

Thinly Traded Securities – UTP

  • *While STA understands and appreciates that the goal of suspending UTP is to enable “innovative market structure solutions”, we have concerns regarding an exchange regime which allows for the suspension of UTP as part of its construct.
  • *As the Commission conducts analysis on UTP suspension filings, it should take into consideration impacts to operational capability and the conditions which encourage enhanced liquidity provision.
  • *Fostering greater operational capability should be the foremost consideration of any regulatory or legislative entity that has oversight or influence on our financial markets. The Commission should consider if one market structure serves operational capability better than another for different types of securities. General areas for consideration could include limiting single points of failure.
  • *Enhanced liquidity is liquidity that exceeds what is publicly displayed and available in the marketplace. A contributing factor in the amount of overall liquidity available is the capital commitment which comes from a subsector of trading centers: market makers, both electronic and traditional; and block traders. Exchanges, by their regulatory requirements are not allowed to commit capital in facilitating liquidity.
  • *While the factors in enhanced liquidity provision are numerous, the Commission should consider the effects of filings which seek to suspend UTP has on certain core ones including:
  • • Quote quality. Displayed liquidity matters, however efforts which seek to increase its levels need to ensure that what is publicly displayed is accessible in a fair and reasonable way.
  • • Volatility. Providers of enhanced liquidity are more inclined to commit capital and more able to conduct block trading if the prices of the security the provider transacts in remains reasonably stable.
  • • Reduction in costs. The withdrawal of market makers and block traders is partially related to the increased costs of trading securities, in particular those of Thinly Traded securities where recouping such costs are difficult.

PDF version here

Comment Letter: FINRA Continuing Education

Comment Letters

The Security Traders Association (“STA”) appreciates the opportunity to offer comments on FINRA Regulatory Notice 18-26 (“Notice”) which seeks industry input on, “…enhancements to the Securities Industry Continuing Education Program (CE Program) under consideration by the Securities Industry/Regulatory Council on Continuing Education (CE Council).”

Comment letter here

Does the World Really Need Another Realtor?

CEO's Desk Women in Finance
 
If you recall, we published an article in June 2017 titled, Lawyers vs. Brokers. In that article we make mention of a then recent comment letter STA filed on FINRA’s lapsed license policy and how it contributes to what we believe is an unreasonable barrier of re-entry to the financial services industry for qualified individuals, particularly those who are primary childcare providers. Effective October 8, 2018, FINRA instituted the Securities Industry Essential (SIE) exam. The SIE exam carries attributes that address some of the concerns expressed in our letter, for example it remains effective for four (4) years after an individual leaves our industry. While much of the work on the new SIE exam was done prior to STA’s comments, we were and remain greatly appreciative that FINRA followed through on it.
 
FINRA is now requesting comment on enhancements to the Securities Industry Continuing Education Program (CE Program). Given how interconnected licenses to practice and continuing education requirements are towards obtaining and maintaining employment in the financial services industry, we applaud FINRA and the Continuing Education Council for soliciting opinions on potential enhancements. We especially want to give FINRA and the CE Council credit for acknowledging in the regulatory notice that the program enhancements being considered would allow individuals to maintain their qualification status following the termination of their registrations in an “effort to address the challenges that industry professionals face when attempting to re-enter the industry after an absence.”
 
Many of us know someone who made a positive impact on our industry and the investors we serve, who then left for an extended period of time to raise a family. When this individual looks to re-enter our industry they face an incredible challenge that is not found in other industries that require a license like: law, accounting or even medicine. Besides facing the burden of getting re-licensed, these individuals are uninformed on current practices because they are unable to take continuing education, again, something that is a unique to our industry. Consequently, many of these individuals seek employment elsewhere resulting in a loss of talent for our industry and many asking themselves, “Does the world really need another realtor?” (No disrespect, we love realtors.)
 

We especially want to give FINRA and the CE Council credit for acknowledging in the regulatory notice that the program enhancements being considered would allow individuals to maintain their qualification status following the termination of their registrations in an “effort to address the challenges that industry professionals face when attempting to re-enter the industry after an absence.”

 
This is an important issue for our industry and we hope you, and your firm, will take a moment to engage on it. STA will accept input from our Advisory Committees until Friday, November 2. If you’d like to offer your opinion, please reach to us at sta@securitytraders.org or better yet, file your remarks with FINRA directly!
 
The regulatory filing is FINRA Notice 18-26 and the deadline for comments is November 5, 2018. STA is currently working on its comment letter, which supports the CE Council pursuing a recommendation to allow previously registered individuals to maintain their qualification status while away from the industry.
 
See STA WIF October Newsletter here

Open Call Report – New FINRA Exam Process

Open Call

In July 2017 the SEC approved FINRA’s proposed rule change to streamline competency exams and expand opportunities for prospective securities professionals

STA Open Call – November 29, 2017 – Call Notes
“New FINRA Exam Process”
Presenter: Joe McDonald, Senior Director Exams & Continuing Education FINRA

Opening Remarks – Jim Toes, STA President & CEO
Senate Tax Bill – The Senate Finance Committee passed a comprehensive tax reform bill. The bill is now being debated by the full Senate. One item of particular concern to STA is a provision that would generally require taxpayers to use a FIFO cost basis on the sale of securities. We published a bulletin publicly and to Hill Staff voicing our objection. link

SEC Commissioner Nominees Update – Nominees for the two (2) SEC Commissioner Positions; Hester Peirce and Robert Jackson received approval from the Senate Banking Committee. They now await approval from the full Senate. Unfortunately, we do not expect this to happen this year.

House Fin’l Services Subcommittee Hearing on CAT – The House Financial Services Committee will be
holding a hearing titled “Implementation and Cybersecurity Protocols of the Consolidated Audit Trail” on November 30th at 10am. Among those testifying will be, Mike Beller, CEO of Thesys Technologies and Chris Concannon, President & COO of Cboe. link

Open Call Summary
In July, 2017 the SEC approved FINRA’s proposed rule change to streamline competency exams and expand opportunities for prospective securities professionals seeking to enter or re-enter the securities
industry. The proposal is a combination of consolidating certain registration rules and restructuring the representative-level qualification examinations by creating a general knowledge examination called the
Securities Industry Essentials (SIE). The SIE is a new, introductory-level FINRA exam for prospective securities industry professionals. The SIE assesses a candidate’s knowledge of basic securities industry information and upon passing is valid for four years. Association with a firm is not required to take the SIE however passing it alone does not qualify an individual to engage in the securities business. Individuals, who do pass the SIE and are then sponsored by a FINRA member firm, need only to take an abridged version of a qualification exam (such as the Series 7). These changes become effective Oct 1, 2018. Please refer to the below links for additional informational on the proposal and how to make a direct inquiry to Joe McDonald.

SEC Approves FINRA Exam and Continuing Education Requirement link

FINRA Securities Industry Essentials Exam, “SIE” link

This brief is meant for informational purposes only and therefore should not be considered legal advice. STA’s goal is to raise awareness and encourage industry dialogue.