From: Lorie J. Smith
Dear Mr. Chairman:
I would like to comment briefly on the proposed rule to ban all investment banks from hiring consultants. I am a small business person with just a couple of clients. I have been a consultant for Citigroup for the past 13 years. When the MSRB started making it a requirement that all G-38 employees adhere to the same restrictions as bankers in that they would not be allowed to give or raise money for politicians, I quit a successful fundraising business.
Over the last ten years, Citigroup has held me accountable by requiring me to sign a form every quarter to document that I had not given any unacceptable contributions. In the meantime, the MSRB relaxed that rule and other independent consultants were allowed to give. It put me at a disadvantage to have to compete with other consultants that were big donors. It also made the industry look bad to have those consultants giving big donations to issuers.
My client had always made it perfectly clear that if you worked for them, you could not give. Therefore, many very political consultants did not want to work for an investment bank as it would limit their ability to give on behalf of other clients. If the MSRB would just enforce the rule as it was and no longer allow consultants to give money, they would not have the problems they are trying to fix. As it is, with this rule change, a small business person like myself will be unable to make a living in the industry that I have been working with for the last 13 years.
You seem like reasonable people. I hope you can see how this change can devestate someone like me who has been following the rules and doing what is right while there is a very simple way to fix the problem without having to put people out of business. Thank you for your consideration of these comments
Lorie J. Smith