April 15, 2011
Thank you for the opportunity to comment on SR-FINRA-2011-016. This proposes to delay the implementation of FINRA Rules 2090 and 2111 from October 2011 to July 2012.
There should not be any more delay with the implementation of these rules. These rules are supposed to incorporate rules that previously existed, with a few changes. If the firms were already complying with the old rules, why would they need an additional 9 months to comply with the new rules?
The implementation of these rules after 9 months (from the announcement approving the proposed rules on January 10, 2011) gives the firms sufficient time to comply with the limited number of changes that were made. Eighteen months is just too long.
Thanks again for the opportunity to comment.
Sincerely,
David Neuman