September 25, 2009
To Whom it May Concern, I am writing to voice my opposition to the above referenced proposal as it places undue burden on independent financial advisors and their broker dealer affiliates. The recent market downturn has caused almost all participants in this industry to figure out how to do more with less resources and the regulatory authorities should not be exempt from the exercise.
FINRA may want to do a better job of long term planning in order to be better able to deal with revenue shortfalls. Doubling the Personnel Assessment is completely unjustified considering the difficult financial environment we all find ourselves in. My understanding of the proposed changes in the GIA is that they place extra burden on independent broker dealers and independent financial advisors. We independent financial advisors should be supported in this difficult time rather than singled out to pay higher fees.
In an effort to be more efficient, maybe FINRA and the SEC can better focus it's efforts on finding large scale fraud and lighten up on searching for trivial infractions of regulations and codes which have very little impact.
Thank you for you kind consideration.
Capital Investment Counsel