On May 26, 2010, the Financial Industry Regulatory Authority (“FINRA”) proposed for public comment new rules (the “Proposed Rules”) that would require, for the first time, that certain “back-office” operations personnel who serve in supervisory capacities qualify and register with FINRA.1 According to FINRA, the Proposed Rules would enhance the regulatory structure surrounding firms’ back-office operations by helping to ensure that investor protection mechanisms are in place in all areas of a member’s business that could potentially harm customers, the firm or the marketplace.

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