Dec. 23, 2022
December 23, 2022 FINRA should consider a less prescriptive approach. The requirements as enumerated are too numerous and onerous on small firms. FINRA should be more concerned with the substance of the review rather than its form. FINRA should also amend the actual rule text instead of adding to the supplemental text. 3110 is already very difficult to follow and FINRA should be reducing complexity rather than adding to it. I also concur with the comments that clearly lay out the history and basis why remote inspections were already permissible.