June 4, 2012
RE: File No. S7-08-07
On Behalf of the National Investment Banking Association, we respectfully request that the SEC extend the comment period for 60 days beyond the June 8, 2012 deadline related to the Amendments to Financial Responsibility Rules for Broker-Dealers on the following merits:
1) the 153 page 2007 proposals are of a scope, complexity, age (5 years ago) and impact, that the current June 8th deadline is not in the public interest nor the industry interest and,
2) the comments made at that time, 5 years ago, may require material changes, or new issues have arisen which would have affected commenters since 2007, so a longer new comment period is warranted and,
3) Given the length of time that has passed since 2007, and the unprecedented changes in the overall industry, more consideration, and not less, should be envisioned by the Commission, which is not in keeping with a June 8th deadline and,
4) The Commission has not updated the statistics or numerical values presented in 2007, or numbers of firms, or costs, and more time should be granted to firms that are, or may be, affected, to analyse the current cost impact of the proposals, since the SEC has not done so prior to the request for new comments due June 8.
Thank you and we urge the Commission to extend the comment period for these important amendment proposals.
The Board of Directors of the National Investment Banking Association.