Sep. 06, 2022
Ladies and Gentlemen – Tobin & Company Securities LLC and its registered representatives are delighted to learn of the proposed rule change to adopt a voluntary, three-year remote inspection pilot program to allow member firms to elect to fulfill our obligation to conduct branch inspections remotely. As a fully dispersed private placements broker-dealer that does not hold accounts, we welcome this much needed update in FINRA’s rules. As a broker dealer with a fully dispersed group of registered representatives who are independent contractors of the broker dealer, it doesn’t make sense anymore to conduct on-site branch inspections. We work with and supervise day-to-day our registered representatives on a remote basis. Most of our registered representatives work from their homes making on-site branch inspections invasive and often uncomfortable. Remote branch inspections would jibe best with our fully dispersed business model and would better align with the post-pandemic business world, especially for small firms like Tobin & Company Securities LLC. Thank you. Justine E. Tobin Managing Partner Tobin & Company Investment Banking Group LLC