September 8, 2009
There are few resources available to potential investors that wish to do due diligence on those that claim to have their best interest at heart and the knowledge base necessary to protect and grow the investor's hard earned savings. Whatever those resources are, especially those resources promulgated by the SRO that claims to have investor protection as their watchword,should be as expansive as possible.
While the proposed rule would eliminate the applicable two (2) year limitation period for just certain types of final regulatory actions, I would recommend that the two (2) year limitation period be eliminated, in its entirety, for any and all information that may be applicable to the prior disciplinary histories of previously registered individuals.
This would include the disclosure of prior arbitration and/or litigation proceedings, terminations for cause, criminal proceedings and all other information that would most certainly be applicable and relevant to both the general public who may be considering a business relationship of trust with the previously registered individual and, of equal if not greater importance, public investors who may be considering the initiation of an arbitration and/or litigation proceeding against an associated person who left the securities industry more than two (2) years ago.
If these past few years have taught us anything it is that we need to shine as much light as possible on those who hold themeselves out as investment professionals, so that the term "full disclosure" is not just a hollow sentiment, but backed by the people charged with protecting the public interest.