September 8, 2009
Thank you for the opportunity to comment on this proposal. I am an attorney, and have been representing public customers in arbitration and litigation against brokers since 1994. I also occasionally represent brokers in employment claims and regulatory proceedings.
FINRA's proposal to slightly expand information provided via its Brokercheck system should be rejected. The SEC should instruct FINRA to devise a complete and meaningful public disclosure of its associated persons' complete CRD. FINRA's current proposal is not even "half a loaf" -- at best, it is but a few crumbs.
Full disclosure of a broker's history is critical for the public to meaningfully evaluate a potential broker. Brokerage firms have access to brokers' complete CRD report, because the information it contains is important in evaluating a broker's character and fitness. The public is entitled to no less.
FINRA claims its goals are "investor protection" and "market integrity." FINRA cannot explain how concealing relevant information about its brokers furthers either of those goals.
FINRA's proposal to provide a very narrow additional disclosure on its Brokercheck system should be rejected.