August 30, 2010
As a former owner of a small broker dealerI have seen what actions thought to be helpful can do to small companies. Sarbanes Oxley had good intentions, but a small privately held broker dealer cannot afford the unnecessary accounting costs of that and effectively compete. The Anti-money laundering testing has good intentions, but the definition of independent testing can cause an unnecessary cost for little benefit.
Large financial organizations like banks put constraints on smaller companies and the larger survive with allowed exemptions to capital requirements not given smaller organizations.
Method of compensation and designation does not guarantee integrity as we have seen in the recent years.
My hope is that you study this issue effectively and objectively and do not put the proverbial harness of an elephant on a flea as a mentor of mine was known to express about certain systems and controls.
Thank you for the opportunity to comment and I wish you well in this endeavor.
John J. Dardis, Sr