April 15, 2009
Florence Harmon
Deputy Secretary, Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Florence Harmon:
I have been a Registered Representative in the financial services industry for seventeen years and work to uphold my standing with peers and clients alike to the highest standards. It has come to my attention that certain proposed changes to FINRA Forms U4 and U5 would require expanded disclosures of arbitration proceedings and civil litigation. I have to object to the part of this proposal that would allow the naming of investment advisor representatives in a lawsuit or arbitration proceeding in which the representative has not been named as a party, and furthermore, have their reputations damaged by unproven claims or allegations made in such proceedings. Everyone should be allowed a fair hearing, and naming someone without being part to a lawsuit or arbitration proceeding unfairly equates them to being representative of said proceeding.
I oppose FINRA's requested changes to Forms U4 and U5 and I hope you will also.
Sincerely,
James Schuberth