From: Geraldine Genco
Jonathan G. Katz
With regard to the proposal to require broker/dealers (and clearing firms) to advise customers on statements to report promptly an(y) inaccuracy or discrepancy- the concept is great. Many firms already comply with this proposal. The addition of the instructions to advise the customer to confirm in writing oral communications is also commendable. However, the weakness is in that firms may rely upon this statement and its disclosure, while customers will typically call or write to the broker on these issues. In fact many firms automatically screen and direct incoming calls and sometimes communications to the broker for response. How likely would that individual be to escalate a "complaint" particularly a verbal one, to a supervisor for action against themselves?
It is probable that the clearing firm would be charged with re-directing the resolution to the firm. Will this give them the additional responsibility to archive, document, investigate or escalate the problem to the proper authority within the executing firm? Is this what is intended?
The firm should be kept in a position of supervision, and client services. It would make sense that the type of communications addressed by this proposal be directed to a specific area within the firm, where this can be managed and supervised. Clients should not be directed to an address or phone number that may lead them back to the individual broker. This proposal, if adopted, should address this procedural issue.