I'm Going as a Conversion Chart for Halloween

Reason? It's the scariest thing I can think of.

Remember when NASD Reg. merged with NYSE reg.? And they said they'd be consolidating the rulebooks? Well, the first set of Rule Conversions was released by FINRA on October 16. For 34 pages of fright, see Notice 08-47 at: http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p117255.pdf

This shows the changes that are effective in 60 days. Many changes are simply adopting current NASD Rules and incorporating old NYSE Rules into brand new FINRA Rules—with no substantive changes. But the quantity of information is scary: 564 items in the handy “Conversion Chart.”
http://www.finra.org/Industry/Regulation/FINRARules/p085560 . This chart shows the old NASD Rule number and the new, corresponding FINRA Rule number (I'm not addressing NYSE Rule changes here, since that's not my area of expertise). That’s helpful, but not as great as it could be. I mean, each of these conversion listings has links to the old and new Rules, the Federal Register with the Rule Filings and approval orders, and any amendments to Rule Filings. The chart doesn’t comment on the nature of the changes represented: minor, technical or substantive. You have to cross reference the Notice (above) for any mention of that. Or open up the Rule Filing and start reading… a lengthy process, for sure.

I've added two columns to the chart: "Summary of Changes" and "In WSP? Changes Necessary?" This way, I'll record the results of my painstaking investigation into each and every cited change. Process: open up 'filing number' link on chart; read summary; open up 'text of proposed rule change' and any amendment links, read 'til I'm cross-eyed, then summarize changes on the table. Next, go to WSP, look for old Rule citations, change them, and add any text necessary to incorporate substantive Rule changes. That's it! I only have 547 items to go. I'm on a roll.

Seriously though, many of these changes relate to things like arbitration claims procedures and other administrative Rules that are generally not included in a firm's WSP. So, maybe in the end only a handful of these announced conversions will result in real written procedural changes. (Wait, this reminds me of the difference between the 'real America' and the, well, not-so-real America and that silly Congresswoman's call for Congressional hearings to route out the fakers... oops, wrong scary blog site...) Anyway, I'm not one to make assumptions and will therefore poke through every item on this chart. I'm praying to the Great Pumpkin and Santa Claus that the next released Conversion Chart will be waaaaaay less lengthy/frightening.

I encourage you to take the time to look at the recent Notice and to open up subsequent bi-monthly Notices. Scroll down through the list of Rule changes for those that are relevant to your business. It certainly won't pay to put off attention to this. Face these demons now: 'tis the season.

Have a sweet Halloween.