March 12, 2009
We would very much be in favor of this change, but the proposed rule change does not go far enough. Besides the limited license the representative should take, a firm only engaging in specific investment banking activities should not be subject to many of the existing rules, including calculation of assessment fees since the revenues are not related to securities transactions; many of the supervisory controls; quarterly focus reports; the requirement to have an audit performed, SIPC, etc. With specific reference for the audited financial statements, smaller firms with revenues less than $10 -25 million should be exempt from this requirement. I am happy to discuss the many other changes that should go along with the limited licensing. Sincerely,Greg
Gregory M. LeNeave
Anderson LeNeave & Co.
6000 Fairview Road, Suite 625
Charlotte, North Carolina 28210