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Dear Madam Secretary,
As the founder and principal of one of the only solely female-owned broker-dealers in the United States, I appreciate the opportunity to comment on SEC Release No. 34-103226. TOBIN, together with its parent company, Tobin & Company Investment Banking Group, that has served issuers, sponsors, investors, and America’s business owners for twenty-five years.
We welcome the improvements offered in the proposed rule change.
However, we agree with Mr. Bellaire of Financial Services Institute in his comment letter dated July 8, 2025 that “a higher threshold for the gift limit” of $500 is most appropriate. Even though FINRA states that it “intends to review periodically the gift limit to determine if further increases are warranted….,” we believe, as do many other members, that history suggests that such reviews are unlikely to occur in practice.
It has been 33 years since the gift limit of $100 was instituted; FINRA has not updated the cap during that time frame. Therefore, a gift limit of $500 is more practical for this rule change.
Thank you for providing the opportunity to comment on this proposed rule change.
Respectfully submitted,
Justine Tobin
Executive Representative and Founder
Tobin & Company Securities LLC
cc: FINRA Small Firm Advisory Committee