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Supervision obligations under FINRA Rules historically have been mostly location-based. But
At least for firms of sufficient sophistication, the rapid adoption of near 100% remote work practices has showcased capabilities built up over the last decade that allow firms to conduct the full scope of their business activities electronically. These capabilities are location agnostic, even if, before the pandemic, they had been largely utilized from within brick-and-mortar locations, whether designated as an office of supervisory jurisdiction (“OSJ”), branch office or non-branch location.
At 2. The SIFMA proposal recognizes that many firms (and indeed other industries) are unlikely simply to the
status quo ante. SIFMA’s proposals include: