September 9, 2009
I am an attorney in private practice in the Washington, D.C. area, and I have regularly represented investors against Broker-Dealers and registered representatives over the last ten years.
I am writing to support the FINRA proposal for expanded availability of information on individuals no longer registered with a brokerage firm. However, I submit that the proposal does not go far enough. All information available through Brokercheck for registered individuals should be available for individuals no longer registered for a period of at least 6-10 years.
Wrongful conduct on the part of representatives may often be hidden from customers, and many customers do not become aware of such conduct until years after it has occurred. This creates a situation whereby investors and attorneys researching the past history of a former representative may not be able to determine the individuals past status and conduct through Brokercheck because two years have passed, forcing one to go through the more difficult process of contacting multiple individual states to investigate.
Furthermore, investors are supposed to be able to use Brokercheck to investigate individuals with whom they may invest, and the public interest is thereby served by making all information available to the public to make such an important decision.
For these reasons I support the proposed change and request that all information be made available for 6 - 10 years after the end of an individual's registration.
W. Scott Greco
GRECO GRECO, P.C.
1300 Old Chain Bridge Rd.
McLean, Virginia 22101