Subject: File No. S7-08-13
From: Thomas Shugrue
Affiliation: President / CEO, Carolina Capital Markets, Inc.

January 27, 2014

Comment Regarding the Proposed Interagency Joint Standards for Assessing Diversity

We want to ensure that there is clarity that diversity under OMWI would not exclude those minorities included under previously enacted equal employment opportunity legislation. Veterans, for example, are included under Public Law 106-50 (Veterans Entrepreneurship Act of 1999). The purpose of this law is “to expand existing and establish new assistance programs for veterans who own or operate small businesses.” Dodd-Frank Section 342, which requires the establishment of OMWI offices, tasks these offices with being “responsible for all matters of the agency relating to diversity in management, employment, and business activities.” Such a mandate requires these offices to be inclusive of previously established minority businesses in addition to ethnic minority and women owned businesses. Our concern is that the entities that fall under these regulations may think that Veterans are no longer included under the diversity initiatives that currently exist. We do not want there to be a misunderstanding about diversity and inclusion. Lastly, CCM, a Veteran owned broker dealer, is actively involved with hiring Veterans. We are affiliated with the Wall Street Warfighters, whose mission is to train Veterans prior to helping them find employment in the financial industry. There is no group that has given up more for our country than our present military employees and recent Veterans. The fact that most of them will be exiting the military prior to achieving a 20 year enlistment, which would have allowed them to receive a pension, should be a concern for every United States citizen.

Yours Truly,
Tom Shugrue


Thomas Shugrue
President / CEO
Carolina Capital Markets, Inc.
400 Meadowmont Village Circle, Suite 429
Chapel Hill, NC  27517