Comment on File No. S7-2026-17, Registered Offering Reform
TOBIN backed the SEC’s push to strip away state-by-state merit review for registered offerings. Her data point: non-traded REIT fundraising collapsed from $33.2 billion to $5.7 billion as issuers fled into private placements to escape the burden. Justine argued that removing duplicative state oversight keeps investor protections intact while bringing capital raises back into the registered, transparent market.
Comment on File No. S7-2026-15:
Proposed Semi-Annual Reporting
When the SEC floated letting companies report every six months instead of quarterly, TOBIN pushed back hard. Her argument: retail investors don’t have Bloomberg terminals, analyst calls, or management access. They depend on regular filings. Cutting reporting in half doesn’t reduce short-termism. It just reduces information for the people who need it most.
Comment on File No. SR-FINRA-2026-004 – Financial Projections and Targeted Returns
FINRA proposed allowing brokers to share financial projections with investors but wrapped it in so many conditions that practically no firm could actually use it. TOBIN called it out: capital markets run on forward-looking analysis, and withholding models from investors isn’t protection, it’s information suppression. She pushed for a workable standard that lets investors see the assumptions behind what they’re being pitched.
Comment on FINRA Regulatory Notice 26-02: Rule Revisions to Help Member Firms Protect Senior Investors From Financial Exploitation and All Investors From Fraud
This one is personal. Justine Tobin’s own 91-year-old mother was financially exploited. When Tobin, a licensed industry professional, raised repeated warnings to the broker, she was ignored because she didn’t hold power-of-attorney. Her brother depleted the accounts before his death in May 2025. She’s now advocating for a rule requiring brokers to document, escalate, and act when licensed professionals raise exploitation concerns, regardless of formal legal standing.
Comment on SEC Release No. 34-103226, Proposed Rule Changed to Amend FINRA Rule 3220 Influencing Employees of Others
The $100 gift limit for broker-dealers hasn’t changed since 1992. TOBIN supported raising it but pushed for $500 rather than the proposal on the table, and she didn’t buy FINRA’s promise to revisit it periodically. Her argument: 33 years proves they won’t.
Comments on Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report
The SEC bundled two major system changes together and called it modernization. TOBIN documented what that actually looked like for a small firm: a six-week enrollment struggle, silent file-naming failures, rejected PDFs, and a $5,000 to $10,000 annual cost increase on top of existing audit burdens. She called for proportionality protections for firms under $250,000 net capital and argued the changes as written accelerate consolidation and squeeze out independent firms.
Comment on FINRA Regulatory Notice 25-07: Modernizing FINRA Rules, Guidance, and Processes for the Organization and Operation of Member Workplaces
FINRA’s rule modernization effort was built around large-firm assumptions. TOBIN spelled out what that costs boutique firms: inspections triggered by routine marketing approvals, enforcement investigations with no defined endpoint, and informal guidance enforced retroactively. She pushed for codified rules, shorter exam cycles, and a framework that treats small firms as professionals, not suspects.
Comment on FINRA Regulatory Notice 25-04: Broad Review to Modernize Rules
A sweeping comment covering six issues at once. TOBIN argued for updating the $100 gift limit, eliminating redundant complaint filings, using AI to standardize advertising interpretations, permitting financial projections for accredited investors, and fixing what she described as enforcement inconsistency that falls harder on women and minority-owned firms.
Comment on FINRA Regulatory Notice 25-05: Outside Business Activities and Private Securities Transactions
TOBIN opposed a proposal that would require her firm to supervise representatives’ work at unaffiliated investment advisers, even though that work is already regulated by the SEC or state authorities. Her position: stacking redundant supervision on boutique firms doesn’t protect anyone. It just slows growth and burns compliance capacity on activities that pose no genuine investor risk.
TOBIN Expands Broker-Dealer Services Internationally
Tobin & Company Securities LLC has announced a new service-line representing broker-dealers from other countries around the world who want to raise capital for their issuer clients by selling securities in the United States. The move means foreign broker-dealers outside the U.S. can access U.S. investment capital and, in turn, institutional U.S. investors can access global […]