January 12, 2009
While its clear that the bd cannot trade ahead of its own report we believe that its customers and potential customers should also be so prohibited and that all customers and potential customers should get the report at the same time. Whether the public should simultaneously get it, should be explored and addressed. There is a recurring suggestion in the news and in certain pending litigation that hedge funds may get preferential knowledge of research in return for trading commissions.FINRA and the SEC should take the opportunity to clarify this area in this proposal.Please accept this comment despite its lateness.
Peter J.Chepucavage
General Counsel
Plexus Consulting LLC