October 28, 2021
FINRA should consider streamlining 3210 in connection with these changes as well. Currently firms face operational challenges in obtaining duplicate statements for associated persons. Some brokerages will not deliver statements electronically, or will not backfill statements that were not received whether because of their error or otherwise. Duplicate statements for industry professionals should not be so difficult to obtain from other member firms and is significant burden that typically yields little substantively. FINRA should also consider whether the CAT can be leveraged. In theory, if the CAT is able to capture the ultimate party behind each trade, we should be able to use it to surveil the activity of registered personnel with it, which would mostly obviate the need for the duplicate statement process. Reviewing reams of paper statements is an antiquated process that we should use the new tools available to replace.