FSI recently submitted a comment letter to the Financial Stability Oversight Council (FSOC) in response to FSOC’s proposed reforms to money market mutual funds. The comments disputed FSOC’s principal determination that additional reform of money market funds is necessary, and drew special attention to a key distinction between prime institutional money market mutual funds (which are the only type of money market funds that have a history of problems) and retail money market funds (which FSI’s members and their clients count on for stability and liquidity).
FSI also sent a comment letter to the SEC after FINRA indicated it is considering changes to an existing rule that would force firms and advisors to include prominently not only a description but individualized links to relevant BrokerCheck entries on all of their websites, social media pages, and “any comparable internet presence” related to a member’s securities business.
While FSI supports efforts to increase investor education with regard to BrokerCheck, our comment letter expresses a number of concerns with the proposed rule change, namely that the language is vague and ambiguous, and, if not revised to provide more clarity, likely to impose considerable unnecessary burdens on firms. In our letter, we asked the SEC to return the proposed rule change to FINRA to allow for additional feedback and further research.