March 22, 2011
I find this rule unfairly burdensome on small broker/dealers such as mine. It is very difficult to compete against the fringe benefit packages offered by larger firms. And with this rule it will be impossible to obtain and retain employees. My employees fill many roles and have done so successfully for many years without incident. In addtion, we are a fully disclosed firm and rely on the expertise of our clearing firm personnel to handle our client's accounts, securities and monies.
We outsource portions of our business for economic purposes. If our independent IT person and professionals of like expertise must be registered with the firm (which will be an impossible task) we will not be able to obtain any reliable help and will be further burdened by additional tasks to run our business.
I realize that I am responsible for my employees and vendors and I believe the additional testing is not called for. It appears that there is no real benefit to the investing public once again. The true winner is FINRA through the fees for testing, continuing education and other potential items it will generate.
I ask that you do not accept this awful rule proposal as it is currently written.