Subject: File No. S7-06-08
From: Richard J Carlesco, Jr
Affiliation: CEO, IBN Financial Services, Inc.

March 13, 2008

Large national broker dealer firms have used this act to keep independent investment professionals from leaving their firms since the act's inception. It is a matter of who owns the client contractually. As an independent investment professional that answer should be clear and was for years that there was no additional disclosure of client information in a block transfer of an independent representatives business all that should be required is a negative response letter informing the client of the move and how it impacts the client. Giving the client the right to stay with the broker dealer they are currently with.

Financial Professionals work their whole careers to acquire a client base and by restricting their ability to move to a new broker dealer only benefits their old broker dealer not the client.

This guidance if done thoughtfully and with respect to all FINRA members large and small could benefit the industry as a whole and move us more in the direction of advisors with the respect of our clients that we serve.