As readers of this publication know, FINRA has proposed its Comprehensive Automated Risk Data System (“CARDS”). The system would require broker-dealers to submit to FINRA, in an automated, standardized format, specific information about their customers’ accounts and the customer accounts of each member firm for which they clear.

Critics of the proposal have focused in particular on the potential threat to investor privacy posed by the significant amount of data that would be recorded electronically. FINRA has responded that, for now, it will not move ahead with the present form of the proposal until it concludes that the relevant concerns have been addressed.