Subject: File No. SR-FINRA-2009-057
From: Richard J. Carlesco Jr. LUTCF
Affiliation: IBN Financial Services, Inc.

September 17, 2009

This again demonstrates FINRA putting more pressure on small Broker Dealers at the benefit of large Broker Dealers. FINRA has no conscience, how much money does FINRA have in the bank? According to last yearís Annual Report they had almost 1.6 Billion Dollars in investments. Last year they had a loss of 23 million dollars at that rate it would take almost 70 years to deplete that account. Now last year was bad sure, however how often does that happen? In the three years prior they made 59 million thatís almost 20 million a year. Based on these numbers FINRA should be reducing our fees as promised in 2007. FINRA only distributed a very small portion of the money they made from the sale of the NASDQ and the merger with NYSE. Their argument for only returning $35,000 to each member was that they would use their investments to reduce fees. That happened one year, that was it. FINRA is becoming a creature out of control and the SEC is the only organization that can rein them in and force them to live up to their commitment. Small Broker Dealers have been reduced to the back seat and the SECís oversight is our only voice. Thank you for the opportunity.

Sincerely,
Richard J. Carlesco Jr. LUTCF
IBN Financial Services, Inc.
8035 Oswego Rd.
PO Box 2365
Liverpool, NY 13089