“The point is that the 211 process has been simplified from the firm's perspective.
I'm guilty along with others here of not always listing the detailed regs and processes when making a statement to that effect.”
It’s not about “listing” or even referencing regs.
But if someone decides they want to make a point about a reg or rule it’s probably a good idea to have some understanding of it…and not completely misrepresent what it is.
And yes the 211 requirement has been made somewhat easier to comply with.
But that “simplification” is NOT the elimination of the 211 altogether, which was one the assertions I was responding to.
And neither was the simplification that “firms” no longer need to file them…well…they never did.
211’s still need to be submitted by broker dealers and approved by FINRA. That isn’t changed.
What has changed is that now an IDQS like OTC Markets can do so. And there was some controversy over this, but that is where it ended up.
There were other technical changes not worth listing here.
If Mark is relying on OTCM to submit it…it will be interesting to see if that works out. He has a lot of well documented baggage.
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