From: E.C. Blitz
There is no doubt the proposed rule is valid and certainly pertinent to a firm that self-clears.
However, for a firm that clears through another B/D directly to the clearing firm, you would think that after the initial application is completed and the client is advised of SIPC coverage, the clearing firm covers this area of concern through their quarterly and yearly statements.
Further, it appears that the requirement for a firm that does not handle money and does not self-clear to subscribe to SIPC is superfluous and unnecessary, but this is a topic for future consideration.
Sometimes, where the rules are designed by humans, the thinking is insufficient and totally misses the point.
E. C. Blitz