Require SROs to conduct cost-benefit analysis on major rules

Research notes

• FINRA’s own practice is visible in its filings; for example the Rule 3290 outside-activities filing at https://www.federalregister.gov/documents/2026/02/03/2026-02122/self-regulatory-organizations-financial-industry-regulatory-authority-inc-notice-of-filing-of-a (2026-02-03) carries an economic impact assessment. It is evidence that the practice continues, not that it was required, and it is recorded here rather than as Evidence for the Status because the Quote asks for a mandate covering all SROs and major rules.
• The only Federal Register documents pairing “cost-benefit analysis” with “self-regulatory organization” in the window are two CFTC rules (2024-31177, 2025-23953) and the SEC’s Consolidated Audit Trail concept release (2026-07651); none creates an SRO analysis duty.
• Cluster negative search for pages 836–837 is recorded in docs/research/ch-27.md.
• The FINRA baseline read (read-queue ticket 07, 2026-09-06) did not reach this ask. finra.org is off the evidence allowlist by design rather than by a wall, and finra.org/rules-guidance/rulebooks/finra-rules/<number> opens to a bare curl — but the host rate-limits hard, answering HTTP 403 to every request for half an hour after four rules were read, through three spaced retries. Rules 9261 and 12904 were read (see #2168 and #2169); the FINRA By-Laws and the Rule 9600 series, which is where an obligation of this kind would sit if one existed, were not. So the question the row asked — whether the practice is binding on FINRA itself — is still open on FINRA’s own documents.
• It is not open on the record that matters here, though, and that is why the Status does not move. The ask is for a requirement covering all SROs. Whether FINRA’s own framework binds FINRA is a fact about one SRO’s internal governance; it cannot make an unimposed requirement imposed, and no instrument in the window imposes one on the exchanges, the MSRB or the NFA.