November 28, 2007
Ladies & Gentlemen;
I applaud FINRA’s attempt to increase transparency and investor knowledge in the area of fixed income securities. Better educated customers are better customers.
I have one recommendation to increase the disclosure requirement: namely, that member firms be required to disclose the details of variable rate fixed income securities on the confirmation of purchase. The vast majority of variable rate fixed income securities as known as step-up notes, in which future interest payments will be increased by known amounts at specified times during the life of the note. Since the future step-up payment rates are known at the time of the transaction, it seems reasonable to disclose that information right on the confirmation, rather than separately. In the vast majority of cases, there are no more than three or four interest steps, which would require far less data space than a complex call schedule. Why be vague when it is so easy to be specific? It seems to me that only in cases of fixed income securities in which future interest payment rates are unknown would it make sense to include some generic statement that the member firm will supply the information separately.
Richard L. Sandow
Southlake Capital Advisors, Inc.
P O Box 92818
Southlake, TX 76092