The suspension imposed on this broker, who allegedly stole a not-huge sum of money from his employer, is much greater than the penalties imposed on brokers who steal far greater sums from elderly customers or persons otherwise unable to protect themselves. FINRA should re-examine whether its penalties are proportionate to the sins for which penalties are imposed.  

The contrast with a recent SEC settlement is notable. The SEC just imposed a six-month suspension (see )…

One compliance point of which to take particular note: the failure of the firm to provide disclosure documents to customers to whom it did not provide custody.  Worthwhile points for other firms to check: (i) whether their provisions of Form CRS are tied to their custodial accounts; and (ii) whether their offering procedures mandate the provision of Form CRS to investors who may not have received the Form previously.  

If the proposed change is adopted, and a bank fails, for any reason whatsoever, commenters would surely say, "I told you so. The bank would not have failed but for the relaxation of standards."  

That said, if a risk is not "material," there is a good argument that it should not be deemed unsafe. If a risk is material, even if unlikely, that may reasonably be regarded as unsafe.  

Firms should take this as a warning to review both their expense sharing agreements and their agreements as to how they allocate revenues and expenses on business activities that involve more than one legal entity; e.g., US and non-US firms operating globally.