August 31, 2009
Why limit the publicly available CRD information to 2 years? Given that the former broker is no longer a broker, that person's privacy interests are hardly worth protecting. Also, inasmuch as the CRD information is necessary for the prosecution of arbitration proceedings against the former broker, the information needs to be available for much longer than two years.
In addition, many former brokers become investment advisors, a largely unregulated industry. Oftentimes the Broker Check system is the only publicly available information on that person.
At a minimum, the Broker Check information on former brokers should remain available for six years after the broker is no longer in the industry. That time period corresponds to the eligibility period for bringing FINRA arbitrations against that person.