September 17, 2009
To whom it may concern:
I object to the proposed increases in PA and GIA (SR-FINRA-2009-057) because I believe the increases are unjustified given the assets and potential income of FINRA and the disproportionately negative impact these increases would have on small firms.
It is apparent from FINRA’s annual report that the organization has more than adequate assets and reserves to withstand the recent downturn. Our wonderful business has suffered enough. As loyal members we have paid into the huge reserves FINRA maintains for many years for just such a season as this. To use the downturn as a justification for increasing assessments is in my view motivated by greed and opportunism. Should revenues increase in the future, we can all assume the assessments will not be lowered.
The increases are unfair to the small firms who make up 80% of FINRA’s membership. By their own admission FINRA states that the decrease in revenue from the large firms is the main culprit in the current cash flow problem. Why subject small firms, who operate on efficient margins, to such increases to compensate for the revenue losses of the large firms? These firms continue to pay large bonuses and their executive salaries are far beyond those earned by owners of small firms.
Unless and until the proposal is altered to more fairly apportion the increase between small firms and large firms I cannot and will not support this proposal. I urge the SEC to reject it in its entirety.
Phillip H. Palmer, ChFC
President and CEO
First Independent Financial Services, Inc. and Affiliates
7134 S. Yale, Suite 560
Tulsa, OK 74136-6352