December 3, 2007
Like so many additions to our regulatory burden, this change appears attractive at first glance. However, it gives the investor the opportunity to review a trade, an opportunity which only the most sophisticated investors would take advantage of. These same investors are able to examine the fairness and appropriateness of trades without the rule change.
The rest of the investing public would gain nothing. It is already dazzled by the paperwork it now receives.
The amount of general "what is a bond?" information to be disclosed is incredible. Does this now take the registered broker-dealer off the hook for selling a bad financial instrument?
If there are improper practices going on in the bond market, let us attack them more directly. I believe that the language of existing rules, although general, gives FINRA and the SEC the tools to go after a pattern of clearly inappropriate bond transactions.
M. E. Midkiff, III
Midkiff & Stone Capital Group, Inc.