August 21, 2014
With regards to trades involving the 17 CFR Part 275 Temporary Rule Regarding Principal Trades With Certain Advisory Clients the Securities and exchange commission has proposed that they would like to amend rule 206 (3)-3T. This falls under the investment advisers act of 1940 which now dates back 74 years ago. This temp. rule has established an alternative means for investment advisers that are properly registered as b-d's (broker dealers) to meet the proper requirements of section 206(3) of the investment advisers act when dealing with certain advisory clients. This is looking to take place for a two year period as of the last day of the calendar 2014 year and will last for a two year period.
As proposed the extension is viable and they should be considered part of a much larger consideration as things go down the road for the next two and half years. This is all with and in consideration of the regulatory requirements applicable to the broker-dealers as well as the investment advisers in connection with the Dodd-Frank Act.
To answer some of the proposed questions:
Should we allow the rule to sunset?
We should extend the ruling as Thomas Michael-Manis or any advisory firm from New York City that trades to wealth management teams that work with Broker Dealers in Boca raton, Florida would agree that it is feasible.
If so, what costs would advisers that currently rely on the rule incur? What would be the impact on their clients?
It should not pass on fees to clients in the first two years. The advisors will have to spend extra time but diligence, hard work, and proper execution is important when dealing in financial markets.
If we allow the rule to sunset, should we consider exemptive requests from investment advisers that are registered with us as broker-dealers for exemptive orders providing an alternative means of compliance with section 206(3)?
We are not advising for sunset.
Are there any developments since the last extension that would make an extension not appropriate?
No comments from Thomas Michael Manis at this current juncture on that but may respond prior to the September deadline on this issue.
If we extend the rules sunset date, is two years an appropriate period of time to extend the sunset date? Or should we extend the rules sunset date for a different period of time?
If so, for how long?
Two years is enough time as financial markets and broker-dealer interactions need time to take place.
Is it appropriate to extend rule 206(3)-3Ts sunset date for a limited period of time in its current form while we complete our broader consideration of the regulatory requirements applicable to broker-dealers and investment advisers?
It is appropriate to extend and the advisors and traders of Thomas Michael Manis will report back on their thoughts and considerations going forward.