Subject: File No. SR-FINRA-2016-015
From: bev kennedy

June 26, 2016

Iiroc has mou s with finra iiroc overseas the behaviour of a dealer broker tdwaterhouse part of td bank group which also conducts business in the USA
Iiroc is neglgient in handling customer complaints re the registration requirements of the above dealer broker as iiroc even though it states that opening accounts is a core vs a non core activity failes to vet the contracts inked with retail investors including the self directed investor to ensure statutory compliance re terms of this contract. As a result iiroc is neglgient in ensuring registrants per the above are fulling compliant with its own rules other relevant contract law and it's own mous re standards with finra. Which means it is not addressing serious customer complaints registrant requirements or fulling it's duties with finra or other global oversight entities thus any exemptions granted by finra re registratants based on the assumption iiroc is fully up to speed are based on flawed premises re iirocs mous and standards. Iiroc has yet to prove it examines these contracts to ensure they are compliant with its own iiroc rules let alone other relevent laws and has yet to explain where tdwaterhouse gets its authority to override and circumvent the law and iirocs rules and ink such blatantly unconscionable terms as laid out in tdwaterhouse lient account agreement page 37 clauses 4 and 5. Compared to iirocs rules re outsourcing and discussion of what is a core outsourced activity and also for example the consolidated ont securities act regs and rules registration requirements business protocol for outsourcing page 621 to 624. Let alone the s e c s concerns re third party outsourcing responsibility and accountability and responsibility the compliance you might wish to review finra own rules re this. This neglgience means that at the initial point of entry to engage and participate iiroc is not insisting that there be a fair playing field let alone vetting to ensure the dealer broker is compliant. In light of this what else is iiroc not doing that finra assumes it is re the mou s to protect all consumers of financial products services and registered entities behaviour?