April 16, 2009
Florence Harmon
Deputy Secretary, Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Florence Harmon:
I am a 30 year insurance agent/financial advisor.I am writing with regard to the changes being proposed by FINRA as they pertain to U4 and U5 reporting.While I adamantly support strong sanctions against unscrupulous sales agents,I believe it to be patently unfair to require an indivual to report on his U4 and U5 any allegations brought simply because he may be named/mentioned in the body of a claim or suit.
It is one thing to require this where a person is guilty of an infraction or even charged.It is quite another to impugn an indivual's reputation where no accusations have even been brought - let alone found guilty.A side issue would be the requirement of U4 and U5 reporting where there are totally unsubstantiated accusations brought against an indivual.Again the mere reporting carries a negative connotation.
I urge you to oppose these regulations being proposed by FINRA.
Sincerely,
Jay Mccluskey