January 17, 2013
COMMENTS ON PROPOSED RULES, REGULATIONS OR AGENCY ACTIONS:
The proposed amendments and new rules would establish capital and margin requirements for nonbank SBSDs, including broker-dealers that are registered as SBSDs (``broker-dealer SBSDs''), and nonbank MSBSPs.
You need to indicate how many entities will be affected by these new rules and how much it will cost them to implement it. I would expect that these additional costs will be passed on to the consumers.
I am for protecting the public and I believe that adequate and clear disclosures in the prospectus is the best tool. The disclosure should be very clear and not in small print and buried among relatively irrelevant data.
ATTORNEY AT LAW