On Oct. 24, FINRA proposed rules on post-office staff conflicts.
- To adopt Rule 9910 post-employment conflict restrictions; nonpublic information.
Ban Ex-Employee Advocacy
- Prohibit former officers from communication or appearance at FINRA, for a year.
- Any ex-employee banned from advocating FINRA at any time in matter involving
specific party with whom personally or substantially involved during employment. - Ban on ex-employees from matters involving a specific party or parties, that was
under the employee’s official responsibility during last year of FINRA employment.
Non-Public Information
- Current employee ban on disseminating or disclosing, in purpose unnecessary to
FINRA job responsibilities, any nonpublic information obtained from empoyment. - Also restrict ex-employee from disseminating or disclosing nonpublic information.
- Unless disclosure expressly authorized by FINRA or required or protected by law.
Effectiveness
- Comment period is until 21 days from pending publication in the federal register.
- FINRA filed proposed rule change for immediate effectiveness, after SEC review.
- Operative date of para (b), (c) and (d) of FINRA Rule 9910 will be Dec. 3, 2018.
- The operative date of paragraph (a) of proposed FINRA Rule 9910, Apr. 1, 2019.
