Dec. 10, 2025
Cascadia Capital’s management team and I (Chief Compliance Officer) are 100% in support of amending CAB Rule 328, to enable associated persons to participate in private securities transactions to the same extent as those of non-CAB FINRA member firms. From the compliance side, I completely understand that we would be subject to the requirements of FINRA Rule 3280 (prior written notice, firm approval/disapproval, and supervision if compensation is involved). This was something I discussed with our FINRA auditors during our recent FINRA audit. The current CAB rule is unnecessarily restrictive, preventing a simple, non-compensated co-investment by an employee which is generally permissible for associated persons at standard broker-dealers under FINRA Rule 3280's notice-only provisions. Eliminating the prohibition would align CABs with other firms, allowing associated persons to participate in PSTs so long as they provide written notice to the CAB, and the CAB can manage the conflict of interest under the framework of FINRA Rule 3280. Please implement this change with our support! And let me know if there are other things I can do to assist you with this. Many thanks, Matt Hoffman Matthew Hoffman Chief Compliance Officer Cascadia Capital, LLC