Attention independents... please review
Please review the following document completely before responding. I am looking for some constructive opinions and feedback. IMO, this is large and could affect your business in the future.
http://www.financialservices.org/MediaLibrary/FSI%20Member%2 0Briefing%20-%20SEC%20Interpretation%20of%20Reg%20S-P%2003-2 7-07.pdf
You are correct as the wirehouses are the big opponents of Reg. S-P but I also understand that not all b/ds are supporting it either. I wanted to get a feel from others who may be more involved in the issue to get a better understanding.
Maybe our resident legal expert (rrbdlawyer) can shed some light.
You might post it over in legal or PM him...he may or may not see it under "what's up".
My experience with LPL is that they only accept public domain information (name, address & phone number) until you open an account, so I'm not sure this applies to that. To your point, they indicated that they would not accept anything else due to privacy issues...
I really didn't find the lack of information to be a serious impediment...transferring a book is time-consuming regardless of the level of information you have. Sure, it would have been a bit easier if I could have simply dropped in a database filled with birthdates, social security numbers, account numbers, etc., but you still have to deal with all your clients...one at a time.
I have historically chastized NASD/NYSE for failing to accept the “regulatory” nature of the issue of expediting client account transfers and for refusing to address the nastiness surrounding departing RRs and their right to contact their clients and inform them about their plans. Ultimately, the most critical concern with this issue is the well-being and security of the clients. Sadly, their interests are lost in this struggle.[/quote]
That, sir, is the heart of this issue and so many other regulatory shortcomings!