December 12, 2007
With regard to the National Association of Realtors application for an exemption from the broker-dealer registration requirements of Sec. 15 and 36 of the Exchange Act of 1934, I would like to offer the following comments.
I am a securities licensed registered representative and own my own broker dealer firm. I have been in the securities business for over 24 years. Before that I was a licensed real estate agent. I believe the request for exemption from registration requirements should be denied. Registration requirements serve to protect the investor. If real estate agents wish to sell securities, they should obtain the required licenses and be held to the same standards of conduct as all licensed registered representatives. Realtors cannot be expected to adequately determine suitability for investors without appropriate financial training. Many real estate agents are part-time and lack formal training. Why should the SEC allow the extensive protections for investors that have been adopted throughout the years by the various regulators to be eroded for the purposes of allowing a real estate agent to sell a security. I do not believe it is in the best interests of the public to exempt real estate agents from the requirements of holding appropriate securities licenses.