April 2, 2005
The adoption of these proposed rules may have substantial unintended consequences for all parties involved in the sale of securities, especially the investor, the broker-dealer and registered representatives.
Of primary concern is that complying with the proposed rules - principally the creation and maintenance of the point of sale disclosure - will be so extremely burdensome and costly that broker/dealers will be forced to limit significantly the number of Covered Securities approved for sale. This is certainly not in the best interests of investors or advisors, as the due diligence done by the broker-dealer is critical to protecting the best interest of both buyer and seller and buyers benefit from having additional choices.
I have just received the notice of this SEC Proposal on Point of Sale & Confirmation Disclosures. That has hardly been enough time to properly react, research and respond.
On this basis I would like the comment period extended for an additional 30 days. Thank you.