February 12, 2013
I appreciate the opportunity to comment on FINRAs proposed changes to amend FINRA Rule 2267. I am an attorney who concentrates his practice on representing investors in securities arbitration and litigation.
I support FINRA's proposed rule. Requiring that firms provide links to the BrokerCheck website will be a beneficial tool to investors. This information is already public, so it should not further harm the registered representatives. The proposed rule will inform customers of public disclosures that they may not be aware of, and I support greater disclosure of material, relevant information. Furthermore, the cost should be relatively minimal to the member firms, who simply just need to provide a hyperlink to BrokerCheck on their websites.
There are some registered representatives who may feel that this is unfair. However, a broker who was been wrongfully accused of misconduct can seek to expunge such accusations from his or her CRD. Moreover, the vast majority of brokers who do not have negative marks on their record should welcome this proposed change.
I would add that the proposed rule should go further and provide the BrokerCheck website on the client's account statements. This should also be a de minimis expense to member firms who are already required to provide these statements to customers.
I want to thank you again for the opportunity to comment on this proposal.