August 31, 2009
It is my belief that the two year lookback period for departing brokers on Broker Check is much too short. If what FINRA is looking for is investor protection by the use of the Broker Check system, then the time period should be longer. For instance, since some brokers depart as registered representatives, but then reappear as registered investment advisors (RIA), it seems that investors would receive more protection if the Broker Check information remained available for a longer period of time. At a very minimum, since the filing elibibility rule at FINRA is six years, the Broker Check information should correspondingly remain available for at least six years from the date that the broker leaves the industry.