Subject: File No. SR-NASD-2003-176
From: Pamela Fritz

August 6, 2004

Comments to Release No. 34-50105; File No. SR-NASD-2003-176

This new proposal, although not requiring CCO certification, still places undue liability not only on the CCO but the CEO. CCOs and CEOs have accepted the responsibility and know the gravity of not having the proper processes in place to detect or better yet prevent non-compliance. Somewhere "reasonably designed" needs to be clearly defined. Even with the best expertise, best intentions and the most current commentaries, to guide the b/d down this path fraught with loopholes, it is possible a regulator could come after a problem arose and was appropriately dealt with by the b/d and consider the process had not been "reasonably designed" to achieve compliance. Hindsight is luxury CCOs and CEOs do not have in the present.

I still believe this whole proposed rule should be scrapped. It will do nothing to bolster investor confidence, still apply too much burden on the compliance departments, will not give the CCO the power nor resources necessary due to internal company polices and politics and still will place squarely on the shoulders of the CCO undue liability.

It is time to look for solutions to problems, not for "whipping boys" and supervisors to blame. Sometimes the blame belongs squarely on those lone renegades where even with all the "perfect" processes in the world, they will find a way to circumvent the system and do the non-compliant thing.

Please reconsider this proposal. If we need a new rule, make one that will go after the wild maverick that got away by jumping the fence, not the one who is diligently guarding the gate.

Pamela Fritz, CCO 
MWA Financial Services, Inc.
309-558-3103
Fax: 309-3150
pfritz@modern-woodmen.org

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