September 30, 2010
I encourage the SEC to base the Ombudsman program on existing Standard, Codes and guidelines provided by the International Ombudsman Association.
I also suggest that the program offer service to the public as required, but also be augmented to serve the workforce at the SEC.
In addition, I am asking the SEC to consider requiring to-code organizational ombudsmen in all regulated firms of more than 500 people as a mechanism to enhance ethical behavior and effective cultures.
Thank you