While SIFMA generally supports FINRA's plans for establishing a registration and CEP for certain operations and support personnel and to adopt NASD Rule 1120 as new FINRA Rule 1250, CE Requirements, with minor changes, it has several concerns.  Managing Director James McHale, writing on behalf of SIFMA expressed the following issues:

        Too Many for Too Short a Period.  Among other things, this proposal would place an undue burden on the industry, given the large number of affected professionals, a new registration category and a scale that's unprecedented. SIFMA also believes that terms and conditions relating to "Day One Operations Professionals" needs to be reworked so as not to impede the ability of a clearing firm to hire and train new staff on a timely basis or quickly replace staff in the event of sudden departures. 

        Covered Persons.   As proposed, covered persons generally would be those “who are directly responsible for overseeing that tasks within the covered functions are performed correctly in accordance with industry rules, firm protocols, policies and procedures and who are charged with protecting the functional and control integrity of the covered functions for a member.”  SIFMA finds the italicized language above particularly helpful in identifying the depth of personnel that FINRA intends to include in the new registration category and respectfully requests that FINRA include this language in the text of the Rule.

Story in progress...........

For further details, go to:   [ SIFMA Comment Letters, 4/29/11. Proposed Ops Professional .." ]