From: Keith E. Condemi
Sent: February 19, 2016
To: rule-comments@sec.gov
Subject: File No. S7-02-16

I support the minimum standard proposed that regulators should require notification to clients of honest communication of the financial condition of broker dealers.  This should include their holding companies.  Otherwise the rule will be limited by clever legal and organization structures designed exclusively to circumvent client notification in the interest of a further lack of transparency.  Broker dealers should not have this capability and circumvention power to avoid notification.  That is a breach of trust at best.  Broker dealers are in a position of great trust provided by clients and the client assets they hold. 

The proposed rule regarding liquidation notification to clients is more than prudent.  In respect broker dealers have been charged with great trust in holding and maintaining clients assets and client wealth.  This should be a minimum standard notification.  A broker dealer who is unable to successfully manage their own financial affairs to cause bankruptcy Chapter 11 or Bankruptcy Chapter 7 should have not have the option to hide this information from client view.  It is at best duplicitous. 

I can think of no greater client protection for both representatives and clients to insure at least clients are notified of these facts.  This comes to representatives also who are in especially difficult situations when broker dealers choose willingly to avoid disclosure to clients.  It places the client interest first.  It places the client first for the representative in a potentially retaliatory environment and career ending situation representatives should not be faced with making that decision.  The regulators should step in and eliminate this current policy and lack of transparency.  Please shine a light on this situation in the interest of clients.

 

Keith

Keith E. Condemi, CFA, OSJ Branch Manager Equimark East®
2376 Monroe Avenue
Rochester, NY 14618