In 1999, it typically cost a several million dollars and several months to implement new business software like a Customer Relationship Management system from Oracle.
With a personal, almost manic, bias to exceed my customers expectation, I now have the opportunity to help influence and get developed solutions that help our customers implement solutions that enable them to improve customer insight and intimacy in a way that delights their customers and exceeds their expectations.
There would however be limited exceptions, as specified in the rule, to permit a broker or dealer to reasonably allocate certain controls and procedures to another registered broker or dealer that, based on its position in the transaction and its relationship with the ultimate customer, can more effectively implement them.