May 12, 2008
Regarding File Number S7-06-08
As an accountant and tax preparer for the past 24 years and a relatively newcomer to world of securities and investments, I find the regulation and control of this industry overwhelming.
Privacy is extremely important in my business of accounting and tax preparation. I have policies in force for both that business and my securities business. From my experience, agencies and broker/dealers have policies to cover the issue of privacy.
I have recently transferred to a smaller broker/dealer because I wanted the personal attention for my business just as my clients expect that of me. I became a registered representative because my clients expressed a desire that I take care of all of their financial matters. It has taken many years to build a trust level of that magnitude. I am a self-employed, single person office. I do not have time to do additional redundant paperwork. Small broker/dealers cannot financially afford to hire extra people to do additional paperwork.
Any independent registered representative should be able to keep the clientele that he/she has and should have the ability to transfer those accounts without privacy being jeopordized. Those clients currently have the opportunity to sign paperwork requesting their desire to follow the representative to his/her new broker/dealer. That option would be severely hindered with this new rule.
Thank you for the opportunity to comment on this proposal.
Patrice R. DeGray
G.A. Repple and Company