May 8, 2008
Comment on File No. # S7-06-08
My name is Melisa Lindsay and I am the Program Manager for the Investment Division of SELCO Community Credit Union in Eugene, OR. On behalf of SELCO Community Credit Union I would like to comment on the recent proposed regulation change regarding the disclosure of Registered Representative information at the time that such person leaves employment to work elsewhere (Part 248 of Regulation S-P; Privacy).
I believe that this type of change in regulation would be detrimental to our business at the Credit Union especially in the cases of successful representatives that build large client/member books of business at the Credit Union and then would leave to work for another financial institution (Bank or Credit Union program). It would potentially put the entire member/client relationship at the Credit Union in jeopardy by allowing them to be solicited by the new employer (potentially a Bank or another Credit Union).
NACUSO intends to comment that it is fine to permit this limited disclosure for the purpose of implementing the agreed protocols between broker/dealers but the permissive sharing of information between consenting parties does not supersede the right of other parties to prevent the sharing of information that the parties agree is trade secrets or is otherwise deemed such by applicable law. We agree with this stand point, however the interests of the members of the Credit Union should be protected and to do that, it seems that supplying contact information for a prior Representative should only be done upon explicit request from the investor.
Thank you for your consideration.
Melisa D. Lindsay
OSJ Supervising Principal, CFS
SFS Division Manager
SELCO Financial Solutions &
CUSO Financial Services, L.P. (Member FINRA/SIPC)
@ SELCO Community Credit Union