FINRA Considering Broker-Dealer ADV
FINRA is seeking comments on a concept proposal to require broker-dealers to deliver an ADV-like point-of-sale disclosure document to retail customers. This broker-dealer ADV would include the types of accounts and services provided, products offered, fees and financial incentives, conflicts, and service limitations. FINRA argues that the coming confluence of RIA and BD regulation under Dodd-Frank makes this concept “even more appropriate, if not an outright necessity.”
OUR TAKE: We believe that broker-dealers will be delivering this BD ADV by the beginning of 2012 if not sooner. FINRA is making its case that it should be the regulator for all retail RIAs and BDs.

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