September 4, 2009
Thank you for the opportunity to comment on this topic. I have been in the investment management business for over twenty years. My past experience includes fund raising, investment analysis, investment reporting and operations. I have seen both the good and the bad in the context of placement agent activities. Given the recent problems that have surfaced its certainly worthwhile for the SEC to consider taking further regulatory action in this area.
My concern is that the further action be tailored to fit the particular problem (pay to play) and not simply be a blanket ban on third party placement activities. In my experience placement agents provide a valuable service for the investor. For the investor, particularly governmental investors, placement agents provide a valuable resource to assist in understanding and evaluating their investment choices. Many investors are simply too small and/or so thinly staffed that they don't have the time to evaluate all the choices for their investment dollars. Placement agents will prequalify the investments they represent helping assure the investor that the opportunity presented meets at least minimum standards.
My suggestion is that the penalties for any pay to play activities by heightened, enforcement stepped up and results highly publicized. Beyond that I recommend that third party placement agents be allowed to operate just as they have in the past. Thank you for allowing me the opportunity to comment.
Ray Wirta