April 28, 2007
I am not in favor of the proposed Amendments to the Net Capital Rule 15c3-1.
The costs estimated to be borne by the industry are exceedinly low as virtually no research was prepared to obtain true costs of capital for introducing broker-dealers.
The statement of "We further estimate that the cost of capital is approximately 5% (see footnote 190)" has no substantiation or authentication.
The referenced footnote 190 proves the lack of evidence as it confirms no research was conducted as they only give an off the cuff estimate and I quote "We estimate this (5%) generally would be the cost to a broker-delaer to obtain a subordinated loan"
I am a broker-dealer. I do not estimate my costs of capital. I irrefutably know that 5% is below the Fed Funds rate of 5.25%,the discount rate of 6.25% and the prime rate of 8.25%.
I could not possibly obtain a $280,000 subordinated loan below the Fed, Discount or Prime rates. I would be fortunate to borrow funds for double the SEC estimate of 5%
The true costs of this proposed amendment were given little time, research and consideration. The true costs need to be calculated and verified before a porposed amendment should even be offered, therefore, I urge all to oppose this proposal.
Introducing Broker/Dealer Principal
Beverly Hills, CA