Subject: File Number S7–09–18
From: Paul Marascalco
Affiliation:

Jul. 23, 2018

I wish to comment on the proposed minimum net worth requirements. I do hope this will not become part of the final proposal. If it does it seems only fair that the Value of the Firm be included under assets.

Also to add. Most of us carry E and O insurance to cover professional liability already. The net worth requirement seems an unnecessary burden on Advisors in light of that.

Thanks You

Paul

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Paul Marascalco
Registered Investment Adviser