November 13, 2015
For some broker-dealers there is limited risk that an associated person would have information that could lead to insider trading. Further, some broker-dealers do not engage in business activities or maintain client or firm accounts that could lead to other sales practice issue, such as front-running. Requiring all broker-dealers to receive written notification and to "approve" outside accounts of their associated persons does not allow flexibility for those firms whose business is such that complying with the proposed rule will do nothing to protect the investing public or the markets. The rule should allow firms to decide based on their business model and potential risks whether or not to require approval of outside accounts and whether the firm must receive statements or transaction reports.