September 24, 2009
I am writing to express my concern about a rule proposal that the Financial Industry Regulatory Authority (FINRA) filed with the Securities and Exchange Commission (SEC) concerning a proposal to change FINRA`s regulatory pricing structure by increasing the Personnel Assessment (PA) and Gross Income Assessment (GIA) fees it charges financial advisors and broker-dealers, respectively. In its filing, FINRA indicates that these changes are needed in order to stabilize revenues used to fund FINRA`s regulatory activities.
I think it is unreasonable for FINRA to request that the fees charged to its broker dealers be doubled during the worst recession in the last 30 years. If we were all facing an electric rate increase of 100%, there would be questions raised about the planning capability of the utility and their need for such an increase at this point in time. And I think those questions need to be raised with the FINRA request. The impact to broker dealers of such a rate increase, when their revenues have already been reduced in the recession, is extremely negative, and may result in additional job cuts to cover the increased expenses. we should be trying to preserve jobs and not eliminate them in our current economy.
I request that the SEC reevaluate FINRA`s rule proposal to increase the PA and GIA it assess on its members and request that FINRA develop an alternative approach to fund raising in an effort to sustain itself.
Mr. Timothy Jones
CJM Wealth Advisers, LTD