FINRA proposed new FINRA rules (replacing the old NASD and NYSE rules) that would govern the registration and qualification of broker-dealer personnel. Under the proposed new rules, FINRA would restructure current qualification examinations, creating a general entry-level examination, together with specialized examinations for different securities activities. In addition, the proposed rules would expand the ability of broker-dealer personnel to take exams unrelated to their current securities activities, and to work for affiliates without losing their broker-dealer qualifications. The proposal includes detailed revisions of many individual registration and qualification requirements. Subject to comments and SEC approval, the proposed new qualification structure will be implemented by FINRA in March 2018.
Lofchie Comment: The proposed registration regime has the potential to provide financial institutions a great deal more flexibility in moving individuals within a group, without being concerned that the individuals will lose their licenses because not currently active with the broker-dealer. The proposal will also allow firms more flexibility to have "back-up" personnel who do work for a broker-dealer affiliate, but who can fill in at the broker-dealer if circumstances require. Firms should attend carefully to the details, but the flexibility afforded by the proposal is something clearly deserving of industry support.
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