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  • John Parmigiani

There has never been a more important time than now!

Today the election for the Small Firm Representative on the FINRA Board of Governors concludes.


So, what does it mean to you to have the right person represent you, the small firm, on the FINRA Board of Governors?


Let me start by giving the rundown on what goes on in plain English. FINRA writes new rules and rule modification proposals all of the time. Most often, the effect of these changes is likely detrimental to small firms. Many of these proposals are vetted by different FINRA committees, including the Small Firm Advisory Committee (SFAC), of which I am a member.  Approximately 5 times a year 10 small firm representatives meet in Washington DC to discuss the proposed new rules or modification proposals.  


What do your representatives do?

Well, if everyone holds their tongue and does not speak up on behalf of small firms then the rules move through the rule making pipeline unchallenged and pass, even though they will most likely hinder small firms. The depth and breadth, not to mention the sheer number, of these proposals is astounding and it is imperative that we have the right people sitting on these committees, councils, and boards to fight the good fight for small firms.


At the SFAC I am lucky to work with a team who are engaged, knowledgeable, experienced, vocal and filled with determination and grit. After hours of research on each topic, we prepare factual evidence for discussion and debate of the rule proposals and/or amendments on behalf of the small firm members;  the window to be heard is tight, so every minute counts. After we deliberate with mostly high-level FINRA executives who are also attorneys, our comments along with our positions on the proposals are passed up to the Board of Governors (BOG).


There the Small Firm BOG representatives deliver our message and further advocate for the cause. Please understand, only a confident, articulate and experienced professional can hold the attention of this audience. Loud mouth table pounding doesn’t get the job done. In fact, it only makes things worse.


We need someone with experience and poise, someone who gets the job done. Paige Pierce is 100% , without question, that person. We need Paige now more than ever. Change is upon us, the environment is getting better, inch by inch. Much of it has to do with the efforts of our still-new CEO, Robert Cook, who is doing an impressive job for small firms, along with the efforts from various committees and the Small Firm representatives on the Board Of Governors such as  Bob Muh, Stephen Kohn and former small firm representatives Mark Cresap and Joe Romano.


I have 100% certainty that, if elected, Paige Pierce will continue to ensure modifications to rule proposals lessen the crushing regulatory burden for small firms.


In the past 18 months, I have witnessed Paige, amongst other things:

·        Spearhead the small firm effort in Congress and with the SEC, PCAOB & FINRA to obtain exemptive relief for small firms from the expensive and time-consuming PCAOB audit requirements;

·        Work diligently in an effort to eliminate, or greatly reduce, numerous regulatory fees that would otherwise negatively impact small firms;

·        Debate hard with FINRA on broker check – CRD system enhancements that would protect our rights and fight current misleading and discriminatory industry disclosure statistics, and more.

This is the time to elect someone who has a passion to make a difference, the background and expertise, work ethic, and hard-earned respect to get the job done for you, for us.


Please, find your card or call FINRA (202-728-8949 – Office of the Corporate Secretary) to get a new one and VOTE FOR PAIGE PIERCE. If you have a friend who is in management of a small firm, please reach out and let them know to VOTE FOR PAIGE PIERCE TODAY.

Today is the last day, make your vote count.


For more on Paige see: https://www.psp-consulting.com/articles/2018/7/29/paige-w-pierce-biography-posted-for-2018-finra-board-election


John Parmigiani

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