New Reg. Category for Operations Professionals: Let's Be Clear About This

Notice 10-25 solicits comments on a new registration category for "Certain Operations Personnel." I only wish they'd have called them "Operations Supervisors" so as to limit the hysteria sure to result when folks hear about this. Okay, maybe I'm the only hysterical person in the room. Consider me a bellwether. (Mais, je prefere "belle-weather.")

Here are two excerpts from the Notice that should calm everyone down:

"Persons subject to the new registration category generally are those persons who are directly responsible for overseeing that tasks within the covered functions are performed correctly in accordance with industry rules, firm protocols, policies and procedures, and who are charged with protecting the functional and control integrity of the covered functions for the firm."

and

"The requirements would not apply to persons who perform a covered function, but whose responsibilities are below these three specified levels, or persons who perform a function ancillary to a covered function or whose function is to serve a role that can be viewed as supportive of, or advisory to, the performance of a covered function, such as internal audit, legal or compliance personnel. Also, the requirements would not apply to persons who are engaged solely in clerical or ministerial activities in any of the covered functions."

It seems to me it's all about supervisors and those with control.  I guess after the comments are received and addressed, we'll have convincing clarity on this, as we normally do when a rule is made effective.

[throat clearing sound]

Alright, maybe there is room for worry, in the end...another quote:

Importantly, those persons subject to the new Operations Professional registration category would be considered associated persons of a firm irrespective of their employing entity and would be subject to all FINRA rules applicable to associated persons and/or registered persons.

So, just like outsourced professionals who are doing work requiring registration and qualification, employees of parent companies, affiliates, etc. will be treated as if they work for the BD. Ah, the long arm of the law gives a bear hug to your whole enterprise...

I'm done for now. Three blog entries in one day? Gotta get back to work.