[Federal Register Volume 85, Number 86 (Monday, May 4, 2020)]
[Notices]
[Pages 26502-26506]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-09374]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88760; File No. SR-FINRA-2020-012]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing and Immediate Effectiveness of a
Proposed Rule Change To Amend FINRA Rule 8312 (FINRA BrokerCheck
Disclosure) To Allow the Dissemination of IAPD Information Through
BrokerCheck
April 28, 2020.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that
on April 22, 2020, Financial Industry Regulatory Authority, Inc.
(``FINRA'') filed with the Securities and Exchange Commission (``SEC''
or ``Commission'') the proposed rule change as described in Items I,
II, and III below, which Items have been prepared by FINRA. FINRA has
designated the proposed rule change as constituting a ``non-
controversial'' rule change under paragraph (f)(6) of Rule 19b-4 under
the Act,\3\ which renders the proposal effective upon receipt of this
filing by the Commission. The Commission is publishing this notice to
solicit comments on the proposed rule change from interested persons.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ 17 CFR 240.19b-4(f)(6). Rule 19b-4(f)(6) requires a self-
regulatory organization to give the Commission written notice of its
intent to file the proposed rule change at least five business days
prior to the date of filing of the proposed rule change, or such
shorter time as designated by the Commission. FINRA has satisfied
this requirement.
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[[Page 26503]]
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
FINRA is proposing to amend FINRA Rule 8312 (FINRA BrokerCheck
Disclosure) to allow the dissemination through BrokerCheck[supreg] of
information already publicly disseminated through the SEC's Investment
Adviser Public Disclosure (``IAPD'') database about registered brokers
who are, or were, licensed as investment adviser representatives. The
proposed rule change also would make non-substantive, technical changes
to FINRA Rule 8312.\4\
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\4\ Specifically, the proposed rule change would define in FINRA
Rule 8312(a)(2) ``a current or former associated person of a
BrokerCheck Firm'' as a ``BrokerCheck Associated Person.'' In
addition, the proposed rule change would require the renumbering of
current paragraph (d) as new paragraph (g) of FINRA Rule 8312, and
the updating of cross references.
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The text of the proposed rule change is available on FINRA's
website at http://www.finra.org, at the principal office of FINRA and
at the Commission's Public Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, FINRA included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. FINRA has prepared summaries, set forth in sections A,
B, and C below, of the most significant aspects of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
(a) BrokerCheck Program
FINRA established the BrokerCheck program (then known as the Public
Disclosure Program) in 1988 to provide investors and the general public
with information on the professional background, business practices,
and conduct of member firms and their associated persons. Since
establishing BrokerCheck, FINRA has regularly assessed the scope and
utility of the information it provides to the public and, as a result,
has made numerous changes to improve the program. These changes have
made BrokerCheck easier to access by expanding the available methods of
requesting information through the program. For instance, initially the
public could request information only via U.S. mail or facsimile. FINRA
subsequently added the ability to submit requests via a toll-free
telephone number in 1991 and then through email in 1997.\5\ Now
BrokerCheck reports are available instantly online at https://brokercheck.finra.org.\6\ FINRA also has increased the amount of
information available through the program. At first, limited employment
history, final disciplinary actions and criminal convictions were
available through BrokerCheck. The information currently available to
investors through BrokerCheck includes registrations brokers hold and
the examinations they have passed, and disclosure information regarding
various criminal, regulatory, customer dispute, termination and
financial matters on current and former FINRA-registered brokerage
firms and brokers.
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\5\ Congress in 1990 amended Exchange Act Section 15A to require
FINRA to establish and maintain a toll-free telephone listing to
receive inquiries regarding disciplinary actions involving its
member firms and their associated persons, and promptly respond to
such inquiries in writing. See Securities Enforcement Remedies and
Penny Stock Reform Act of 1990, Public Law 101-429, 104 Stat. 931
(1990). See also Notice to Members 00-16 (March 2000).
\6\ In 2006 Congress again amended Exchange Act Section 15A to,
among other things, expand the methods by which BrokerCheck
information is made available. See Military Personnel Financial
Services Protection Act, Public Law 109-290, 120 Stat. 1317 (2006).
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The information displayed through BrokerCheck is derived from the
Central Registration Depository (``CRD[supreg]'').\7\ The CRD system is
the central licensing and registration system used by the U.S.
securities industry and its regulators. In general, information in the
CRD system is obtained through the uniform registration forms that
firms and regulatory authorities complete as part of the securities
industry registration and licensing process.\8\ These forms,
particularly Forms U4 and U5, collect administrative, regulatory,
criminal history, customer complaint and other information about
brokers.\9\ FINRA, state and other regulatory authorities use this
information in connection with their licensing and regulatory
activities, and member firms use this information to help them make
informed employment decisions. As of March 31, 2020, FINRA had
processed over 56 million registration approvals for brokers and
investment adviser representatives in the CRD system over a period
spanning more than 20 years.
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\7\ The concept for the CRD system was developed by FINRA
jointly with the North American Securities Administrators
Association (``NASAA''), and NASAA and state regulators play a
critical role in its ongoing development and implementation. FINRA
operates the CRD system pursuant to policies developed jointly with
NASAA. FINRA works with the SEC, NASAA and other members of the
regulatory community to ensure that information submitted and
maintained in the CRD system is accurate and complete.
\8\ The uniform registration forms are Form BD (Uniform
Application for Broker-Dealer Registration), Form BDW (Uniform
Request for Broker-Dealer Withdrawal), Form BR (Uniform Branch
Office Registration Form), Form U4 (Uniform Application for
Securities Industry Registration or Transfer), Form U5 (Uniform
Termination Notice for Securities Industry Registration), and Form
U6 (Uniform Disciplinary Action Reporting Form).
\9\ FINRA and NASAA jointly drafted the Forms U4 and U5, and
both organizations collaborate in the development of any proposed
amendments to these Forms.
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Pursuant to rules approved by the SEC, FINRA makes specified
information in the CRD system publicly available through
BrokerCheck.\10\ BrokerCheck is part of FINRA's ongoing effort to help
investors make informed choices about the brokers and broker-dealer
firms with which they may conduct business. BrokerCheck maintains
information on the approximately 3,610 registered broker-dealer firms
and 625,000 registered brokers. BrokerCheck also provides the public
with access to information about formerly registered broker-dealer
firms and brokers.\11\ In 2019 alone, BrokerCheck helped users conduct
almost 41 million searches of firms and brokers.
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\10\ There is a limited amount of information in the CRD system
that FINRA does not display through BrokerCheck, including personal
or confidential information. A detailed description of the
information made available through BrokerCheck is available at
https://www.finra.org/investors/learn-to-invest/choosing-investment-professional/about-brokercheck.
\11\ Formerly registered brokers, although no longer in the
securities industry in a registered capacity, may work in other
investment-related industries or may seek to attain other positions
of trust with potential investors. BrokerCheck provides information
on more than 16,900 formerly registered broker-dealer firms and
564,000 formerly registered brokers. Broker records are available
through BrokerCheck for 10 years after a broker leaves the industry,
and records of brokers who are the subject of disciplinary actions
and certain other events remain on BrokerCheck permanently.
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(b) IAPD Database
IAPD provides information about both SEC-registered and state-
registered investment adviser firms, certain investment adviser firms
that are exempt from registration with the SEC or states, and state-
registered investment adviser representatives. The information in IAPD
is derived from the Investment Adviser Registration Depository
(``IARD''), an electronic filing system sponsored by the SEC and NASAA
that collects and maintains the registration, reporting and disclosure
information for
[[Page 26504]]
investment advisers and related persons.
BrokerCheck and IAPD have many similarities. For example, both
systems display information about individuals that has been filed with
the CRD system on Forms U4, U5 and U6.\12\ In addition, information on
many registered individuals can be obtained in either system because
the majority of brokers are also registered as investment adviser
representatives and vice versa.\13\ Despite the similarities, there are
some differences between BrokerCheck and IAPD, including the
information available, the presentation format, and the manner in which
users may obtain information from the systems. For instance, the
systems display different information pertaining to professional
designations, passed qualification examinations, and registrations. The
systems differ also in the manner in which detailed information about
firms is made available to users. BrokerCheck displays a report that is
developed from the information reported on Forms BD and BDW whereas
IAPD provides links to the most recently filed Form ADV, Uniform
Application for Investment Adviser Registration and Report by Exempt
Reporting Advisers, and the Form ADV Part 2 Brochures in a Portable
Document Format (``PDF'').
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\12\ With respect to investment adviser representatives, IARD
provides for the filing of these Forms through the CRD system.
\13\ To help investors access information on the minority of
individuals who are not dually registered, FINRA in 2012 unified the
search returns for the IAPD and BrokerCheck databases. This change
resulted from a study released by SEC staff in January 2011 that
included recommendations on improving investor access to investment
adviser and broker-dealer registration information. The study was
required by Section 919B of the Dodd-Frank Wall Street Reform and
Consumer Protection Act, Public Law 111-203, 124 Stat. 1376 (2010).
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(c) Display of Additional Investment Adviser Representative Information
The SEC's Investor Advisory Committee (``IAC'') recommended the
development of more complete, simple and centrally operated search
functions that permit thorough understanding of the background of those
offering financial products and financial advice.\14\ Shortly after the
IAC's recommendations were issued, FINRA and SEC staff began discussing
how best to align changes to IAPD under consideration by the SEC with
possible changes to BrokerCheck to provide users with more
comprehensive, consistent, and easier access to information already
publicly disseminated about individuals that is contained in both
systems. On February 15, 2020, the SEC implemented changes to IAPD to
display information that is already publicly disseminated through
BrokerCheck.\15\ As such, FINRA is proposing to amend Rule 8312 to make
corresponding changes to allow the dissemination through BrokerCheck of
information already publicly disseminated through IAPD about registered
brokers who are, or were, licensed as investment adviser
representatives. This change would allow users of BrokerCheck to obtain
the available information about these individuals in a single search of
BrokerCheck or IAPD and thereby minimize the need to access multiple
databases.\16\
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\14\ The IAC's recommendations are available at https://www.sec.gov/spotlight/investor-advisory-committee-2012/final_iac_backgroundcheck_recommendation_071615.pdf.
\15\ This information includes self-regulatory organization and
state broker licenses, and broker qualification exams passed.
\16\ FINRA notes that the proposed rule change would impact
members that have elected to be treated as capital acquisition
brokers (``CABs''), given that the CAB rule set incorporates the
impacted FINRA rule by reference.
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(d) Proposed Amendments
As previously discussed, information about brokers and investment
adviser representatives is filed with the CRD system through certain
registration forms. Some of the information reported for an investment
adviser representative is displayed in BrokerCheck if such an
individual also has, at some point, been registered as a broker.
Specifically, the following information reported by an investment
adviser representative (if displayed in IAPD) is made available through
BrokerCheck:
Current investment adviser firm (applies only to a
currently registered investment adviser representative);
identifying information (name changes, other names);
employment history for the past 10 years;
state qualification exams passed;
other business activities; and
disclosure events (excluding historic disclosure
events).\17\
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\17\ Historic disclosure events (i.e., certain disclosure events
involving customer dispute information reported in the CRD system
that became no longer reportable after an individual's first
investment adviser representative registration was approved but
before the individual's first broker registration was approved)
currently are not included in BrokerCheck.
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FINRA proposes to add new paragraph (d) to FINRA Rule 8312 to
provide that FINRA may release through BrokerCheck information already
publicly disseminated through IAPD about a BrokerCheck Associated
Person currently associated with a BrokerCheck Firm who is, or was,
licensed as an investment adviser representative.\18\ Accordingly,
under the proposed rule change, the following additional information
would be displayed through BrokerCheck for those individuals who are
currently dually registered as a broker and an investment adviser
representative:
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\18\ A ``BrokerCheck Firm'' is a current or former FINRA member
or a current or former member of a registered national securities
exchange that uses CRD for registration purposes. See FINRA Rule
8312(a)(1). See also supra note 4.
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State investment adviser representative licenses;
current and past investment adviser firms, registered
branches, and non-registered locations that are not private residences
where the individual is or was registered;
historic disclosure events; and
professional designations.\19\
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\19\ Should the SEC in the future make additional categories of
information about investment adviser representatives publicly
available in IAPD, FINRA will consult with the SEC regarding the
dissemination of the additional information through BrokerCheck. The
dissemination through BrokerCheck of the additional information may
apply to those individuals who are currently dually registered as a
broker and an investment adviser representative, as well as those
individuals who are currently registered as a broker and were
previously registered as an investment adviser representative.
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In addition, for those individuals who are currently registered as
brokers and were previously registered as investment adviser
representatives, BrokerCheck would display all of the publicly
disseminated additional investment adviser representative information
listed above, except for professional designations because a previously
reported professional designation may no longer be in effect. However,
if a registered broker currently holds a professional designation, this
information would be displayed through BrokerCheck if reported by the
broker via Form U4.
For any individual who currently is not registered as a broker,
such as a currently registered investment adviser representative who
was formerly registered as a broker, the additional investment adviser
representative information referenced above would not be displayed
through BrokerCheck. As it does today, BrokerCheck would continue to
include a link to IAPD for those individuals who are or were previously
registered in an investment adviser representative capacity so that
investors could obtain further information about such individuals in
that system.\20\ Furthermore, FINRA
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plans to add a notation in BrokerCheck for formerly registered brokers
who currently are registered as investment adviser representatives
indicating that more current information regarding the investment
professional is available in IAPD.
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\20\ Similarly, with respect to firms, BrokerCheck will continue
to include a link to the summary page of IAPD for a broker-dealer
that also is registered as an investment adviser. From the IAPD
summary page, users can easily view a PDF version of the most
recently filed Form ADV for that firm. In addition, Form CRS will be
accessible through BrokerCheck and IAPD upon its implementation in
2020. See Form CRS Relationship Summary; Amendments to Form ADV,
Securities Exchange Act Release No. 86032 (June 5, 2019), 84 FR
33492 (July 12, 2019).
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FINRA has filed the proposed rule change for immediate
effectiveness. FINRA anticipates that the implementation date of the
proposed rule change will be June 20, 2020.
2. Statutory Basis
FINRA believes that the proposed rule change is consistent with the
provisions of Section 15A(b)(6) of the Act,\21\ which requires, among
other things, that FINRA rules must be designed to prevent fraudulent
and manipulative acts and practices, to promote just and equitable
principles of trade, and, in general, to protect investors and the
public interest.
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\21\ 15 U.S.C. 78o-3(b)(6).
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Following ongoing discussions with SEC staff, FINRA is proposing to
amend Rule 8312 to allow the dissemination through BrokerCheck of
information already publicly disseminated through IAPD about registered
brokers who are, or were, licensed as investment adviser
representatives. The proposed rule change will align BrokerCheck with
the changes the SEC implemented to IAPD on February 15, 2020, and will
allow investors and other users of BrokerCheck to obtain the available
information that already is publicly disseminated about these
individuals in a single search of BrokerCheck or IAPD and thereby
minimize the need to access multiple systems. FINRA believes that the
proposed rule change will provide investors and other users of
BrokerCheck with more consistent and easier access to information about
the investment professionals with which they may conduct business
because it will result in BrokerCheck displaying the same level of
information that currently is available in IAPD.
B. Self-Regulatory Organization's Statement on Burden on Competition
FINRA does not believe that the proposed rule change will result in
any burden on competition that is not necessary or appropriate in
furtherance of the purposes of the Act.
Economic Impact Assessment
FINRA has undertaken an economic impact assessment, as set forth
below, to further analyze the regulatory need for the proposed rule
change, its potential economic impacts, including anticipated costs,
benefits, and distributional and competitive effects, relative to the
current baseline, and the alternatives FINRA considered in assessing
how best to meet its regulatory objective.
Regulatory Need
BrokerCheck provides the public with information on the
professional background, business practices, and conduct of FINRA
member firms and their associated persons. FINRA believes, however,
that changes to the information presented in BrokerCheck can make
BrokerCheck more useful for investors and other users of the system.
Accordingly, FINRA is proposing to add to BrokerCheck investment
adviser representative information for those individuals who are
currently registered as brokers, and who are currently or were
previously registered as investment adviser representatives.
Economic Baseline
The economic baseline for the rule change is the current rule that
addresses the types of information displayed in BrokerCheck. The
proposal is expected to affect users of BrokerCheck, and currently and
formerly registered firms and individuals. Users of BrokerCheck include
investors, member firms and other entities in the financial services
industry, and individuals registered as brokers or seeking employment
in the brokerage industry.
The information displayed in BrokerCheck is derived from the CRD
system. In general, the information enables users to make informed
decisions regarding the firms currently registered as broker-dealers
and the individuals currently registered as brokers. Decisions include
the choice of firms or individuals to do business with or employ, and
the choice of firms with which to seek employment.
The ability of users to access and review information related to
individual brokers through BrokerCheck is constrained by certain
limitations. One of these limitations is that BrokerCheck currently
provides indirect access to information describing the investment
advisory business of a broker, requiring users to access a separate
system (IAPD) to gather additional information that could be relevant
to their decision. The need to access a separate system increases
users' search costs and reduces their ability to research and compare
information about individuals in the brokerage industry.
Economic Impacts
The proposed rule change would increase the amount of investment
adviser information available or accessible through BrokerCheck, but
would not change the aggregate information available to users of
BrokerCheck and IAPD. Users of BrokerCheck would no longer need to
access a separate system--IAPD--to obtain the information for
individuals currently registered as brokers who are, or were, licensed
as investment adviser representatives.\22\ The ability to review this
information in a more efficient manner would reduce user search costs,
particularly for users that seek individuals who are experienced in or
can offer both brokerage and advisory services. These users would also
benefit by doing business with or employing individuals or firms with
individuals that are experienced in or can offer services more closely
aligned with their needs, thereby increasing their economic welfare.
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\22\ BrokerCheck maintains information on 3,610 firms currently
registered as broker-dealers and 625,000 individuals currently
registered as brokers. Among the firms currently registered as
broker-dealers, 526 (15 percent) are currently registered as
investment advisers and 130 (four percent) were formerly registered
as investment advisers. Similarly, among the individuals currently
registered as brokers, 295,120 (47 percent) are currently registered
as investment adviser representatives, and 16,458 (three percent)
were formerly registered as investment adviser representatives.
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Information that may become available or more accessible through
BrokerCheck includes information relating to historic disclosure events
of investment adviser representatives. Disclosure events reported to
the CRD system, which include customer complaints, have been found to
be predictive of future misconduct.\23\ The review and consideration of
this additional information before the selection of an individual with
whom to do business or to employ may improve investor protections by
increasing the ability of users to understand the potential risk of
misconduct. It is anticipated, however, that there will not be a
significant number of Historic Disclosure events to be displayed
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through BrokerCheck. The economic impact of this aspect of the proposed
rule change, therefore, is expected to be limited.
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\23\ See Hammad Qureshi & Jonathan Sokobin, Do Investors Have
Valuable Information About Brokers? (2015), https://www.finra.org/sites/default/files/OCE-Working-Paper.pdf. See also Mark Egan,
Gregor Matvos & Amit Seru, The Market for Financial Adviser
Misconduct, 127(1) Journal of Political Economy 233-295 (2019); and
Stephen G. Dimmock, & William C. Gerken, Predicting Fraud by
Investment Managers, 105(1) Journal of Financial Economics 153-173
(2012).
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The proposed rule change is not expected to harm or hinder
competition among individuals currently registered as brokers who were
previously registered as investment adviser representatives. Under the
proposed rule change, similar past employment information as an
investment adviser representative would be displayed through
BrokerCheck regardless of whether that previous employment was at (1) a
firm dually registered as a broker-dealer and an investment adviser, or
(2) a firm solely registered as an investment adviser. Information is
also currently available through IAPD describing the investment adviser
firms at which the individuals were previously employed.
Alternatives Considered
No alternatives were considered for this proposed rule change.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
Written comments were neither solicited nor received.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Because the foregoing proposed rule change does not: (i)
Significantly affect the protection of investors or the public
interest; (ii) impose any significant burden on competition; and (iii)
become operative for 30 days from the date on which it was filed, or
such shorter time as the Commission may designate, it has become
effective pursuant to Section 19(b)(3)(A) of the Act \24\ and Rule 19b-
4(f)(6) thereunder.\25\
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\24\ 15 U.S.C. 78s(b)(3)(A).
\25\ 17 CFR 240.19b-4(f)(6).
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At any time within 60 days of the filing of the proposed rule
change, the Commission summarily may temporarily suspend such rule
change if it appears to the Commission that such action is necessary or
appropriate in the public interest, for the protection of investors, or
otherwise in furtherance of the purposes of the Act. If the Commission
takes such action, the Commission shall institute proceedings to
determine whether the proposed rule should be approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's internet comment form (http://www.sec.gov/rules/sro.shtml); or
Send an email to [email protected]. Please include
File Number SR-FINRA-2020-012 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.
All submissions should refer to File Number SR-FINRA-2020-012. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's internet website (http://www.sec.gov/rules/sro.shtml).
Copies of the submission, all subsequent amendments, all written
statements with respect to the proposed rule change that are filed with
the Commission, and all written communications relating to the proposed
rule change between the Commission and any person, other than those
that may be withheld from the public in accordance with the provisions
of 5 U.S.C. 552, will be available for website viewing and printing in
the Commission's Public Reference Room, 100 F Street NE, Washington, DC
20549, on official business days between the hours of 10 a.m. and 3
p.m. Copies of such filing also will be available for inspection and
copying at the principal office of FINRA. All comments received will be
posted without change. Persons submitting comments are cautioned that
we do not redact or edit personal identifying information from comment
submissions. You should submit only information that you wish to make
available publicly. All submissions should refer to File Number SR-
FINRA-2020-012 and should be submitted on or before May 26, 2020.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\26\
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\26\ 17 CFR 200.30-3(a)(12).
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J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-09374 Filed 5-1-20; 8:45 am]
BILLING CODE 8011-01-P