August 2, 2011
I appreciate the opportunity to respond to the Securities and Exchange Commission's request for comment to proposed amendments to the broker-dealer financial reporting rule under the Securities Exchange Act of 1934 (the Exchange Act
The Annual Reporting Amendments proposed in this release, if adopted, would markedly improve PCAOB inspection and oversight authority over broker-dealer independent public accountants and enhance existing audit controls, identify broker-dealer entities with weak custody practices and help safeguard investor assets.
I believe the representations made in the proposed Compliance Report, prepared by the carrying broker-dealer and Examination Report, prepared by the broker-dealers independent public accountant would instill greater confidence in the capital markets in general, and the individual institutions, in particular.
I commend the SEC for its efforts to encourage greater transparency and suggest proactive steps for firms to adopt adequate internal custody and risk management controls.