September 28, 2009
I must object with the proposed hike in fee assessments by FINRA. As prudent financial professionals, it is our responsibility to prepare for inevitable downturns in business, especially when they ARE CLEARLY IN THE MAKING as they were in 2007 and 2008. It would be wrong to go to our clients and demand higher fees or commissions just because WE HADN`T PREPARED. Your response would be very critical of actions like that, and they should be, so why is doing this very thing to the brokerage community by FINRA approprate?
The proposal that the Financial Industry Regulatory Authority (FINRA) filed with the Securities and Exchange Commission (SEC) concerning increasing the Personnel Assessment (PA) and Gross Income Assessment (GIA) fees it charges financial advisors and broker-dealers, is flat out wrong and (dare I say it?) Greedy.
I believe FINRA`s failure to properly prepare for the inevitable market downturn is the root cause of their operating cash flow concerns. It is unfair to burden broker-dealers, financial advisors and their clients, all of whom have all suffered greatly during the recent market downturn, with these additional fee assessments. More specifically, the doubling of the PA is simply unjustified by any reasonable calculation of inflation over the five-year period since the last increase in the PA. Additionally, the proposed method of calculation for the GIA will only heighten the disproportionate regulatory cost borne by independent broker-dealers, financial advisors, and their clients.
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. Penn Rettig
Multi Financial Securities Corp