The IAA objects to FINRA’s questions on whether standards for complex products and options should apply to investment advisers because FINRA has no authority over investment advisers.
FINRA recently published guidance outlining when CCOs’ role is advisory and when CCOs may be liable for failing to discharge their supervisory responsibilities.
The rules generally prohibit allocations to broker-dealers, investment advisers, and others that own or control, directly or indirectly, more than 10 percent of a broker-dealer.
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