April 27, 2007
I am opposed to the Amendments to the Net CApital Rule 15c3-1 as printed on page 12885 of the Federal Register/Vol. 72 No.52.
This unjust proposal will not provide a more accurate picture of the financial condition of Broker-Dealers to investors and regulators. Rather, this proposal will serve only to severly weaken the financial condition of these firms. The investing public will be denied their opportunity and right to employ smaller, often independant firms, as this amendment will drive the 702 mentioned introducing firms out of the industry
The anti-small firm discriminatory proposal will require the 702 mentioned debt-free Introducing Broker-Dealers to needlessly take on debt of approximately $280,000
There is no cause for Broker-Dealers whom report zero liabilities on FOCUS filings to be unilaterally forced to raise their firms' net capital requirments 5000% just because other firms carry an averave liability of $280,354. Rather, these firms should be commneded for their strong balance sheets.
The results, should this burdensome proposal be approved, would force the makority of small firms out of business and ultimately deny investors the right and opportunity to deal with smaller, more personalized and debt-free member firms.
I urge all to oppose this amendment