From: Joe Delaney
Sent: September 6, 2016
Subject: File No. S7-13-16 - Adviser Business Continuity and Transition Plans

J.V. Delaney & Associates
A Registered Investment Advisor
An Affiliate of J.V. Delaney & Associates, a Member of FINRA
And a Registered Broker-Dealer with the Securities & Exchange Commission
Est. 1981


Dear Mr. Fields:

The Adviser Business Continuity and Transition Plansproposal will be anti-small business, costly, duplicative, anti-small business formation and will not benefit investors.

This 96 page proposal is a burden just to read for a small business. I wish I had the likes of Messrs. Granito, Ryan and Blass on my staff to review the constant flow of new proposed regulations.

Regulations are a big part of the reason the number of broker-dealers is almost half of what it was in 1984.

I think if this proposal was known by more advisors you would have a thousand comments against it. Please extend the comment period.

I largely agree with the comments of Messrs. Granito, Ryan, Day, Blass, Shanzer and Silver.

Additionally, this proposal if approved will in time be adopted in some form by state regulators and FINRA creating even more costs for small businesses.

Please drop your proposal.


Joe  Delaney

Cc: Hon. Dana Rohrabacher, California’s 48th Congressional District