Subject: File No. SR-FINRA-2009-039
From: Joe Giordano
Affiliation: President, Joseph James Financial Services, Inc.

July 14, 2009

July 14, 2009

Dear Ms. Harmon:

My comment is about the proposed rule change regarding FINRA Rule 3310 that will be part of the Consolidated FINRA Rulebook. The proposed rule would eliminate the current exemption that allows small firms to use someone within the firm to fullfill the AML requirement.

As owner and President of a small broker/dealer for over 23 years in our community we have served the small and middle income clients with one on one service. Many of the larger firms would send these smaller size clients to a call center or not even bother to provide them with service. Our ability to continue to provide services to our clients is to control the cost associated with that service. Many of our clients have been with us for many years. It is not like a bank where new people are coming and going all the time. The current rule allows us to complete the AML testing without adding new cost for a small firm.

Please reconsider the deletion of this exemption that is available to small firms.

Thank you for your time in this matter.


Joe Giordano, CFP
Joseph James Financial Services, Inc.