From: Teri Cox [tcox@cnb-enid.com]
Sent: Tuesday, June 12, 2001 11:00 AM
To: rule-comments@sec.gov
Subject: File No. S7-12-01

Our concerns are that in the past, as a bank, we have been governed by regulations that allow us to pay
nominal referral fees to our employees (including but not limited to non-agent employees) IF the fee did not
require the customer to actually purchase a product.  In other words, if the customer kept an appointment,
that was all that was necessary.  The regulations do not define nominal and for most bank it is somewhere in
the amount of $15 - $25.

The new revision now seems to make the referral fee fall under SEC rules for Banks due to the relationship
between the broker and the Bank.  The new rule seems to say that the fee must be nominal and then describes
nominal as "not more than one hour's pay for the non-agent employee."  Is this true?  Does this really
restrict Bank's on how much they can pay as a referral fee?  Naturally, the problem is, the Bank would have to
pay different referral fees based on the individual's hourly pay rate.  That would be a night mare!  It makes
much more sense to pay a flat rate.  
 
For example, if we are only allowed to pay someone $7.00 for a referral fee, the amount that the employee
would net after taxes would be less than $5.00.  This is hardly enough to encourage anyone to make a referral.

Thank you for your consideration.

Teri Jones Cox
Vice President, HR/Compliance
Central National Bank
Enid, OK
(580) 213-1630
(580) 249-5941 (fax)