July 10, 2009
July 10, 2009
Ms. Harmon:
I would like to take this opportunity to comment on the proposed rule change regarding FINRA Rule 3310 as part of the Consolidated FINRA Rulebook.
I am an owner and officer of a small broker-dealer which has served our community for over 60 years. I have also served as chairman of the Small Firm committee of SIFMA and participated in many meetings and discussions with NASD, SEC and FINRA regarding rule adoptions particularly as it relates to small firms.
The proposed rule removes the current exemption that allows small firms, due to their limited size, the ability to use someone from within the firm to conduct AML testing.
I would point out this is a removal of one of the few carve out rules available to small firms. We, due to limited resources of time, personal and money are once again disproportionately, versus large firms, negatively impacted by this change.
Please consider the removal of this important exemption which will affect thousands of small firms through out the country.
Thank you again for your consideration in this matter.
Trubee, Collins Co., Inc.
William R. Pictor
President, CCO