June 29, 2011
File No. S7-18-11
Proposed Rules for Nationally Recognized Statistical Rating Organizations
File No. S7-21-11
Disqualification of Felons and Other "Bad Actors" From Rule 506 Offerings
File No. S7-17-11
Investment Adviser Performance Compensation
File No. 4-629
Solicitation of Comment to Assist in Study on Assigned Credit Ratings
File No. 4-627
Short Sale Reporting Study Required by Dodd-Frank Act Section 417(a)(2)
In reviewing the above SEC proposed rules that have been submitted for comment, I must admit that I am in total awe regarding the level of micromanagement coming from the members of congress that passed the Dodd-Frank bill. Though I have barely nicked the surface of my knowledge of the provisions included in this voluminous bill, my brief review of just the above 5 provisions, combined with articles that I have read in the press, as well as what I have gleamed from various training classes, has given me the distinct impression that all our country is going to get out of this entire financial fiasco, is just more of the same. Even more complicated rules and regulation with lots of exceptions, costing companies and taxpayers even more money to police and enforce.
It truly appears to me, that the Dodd-Frank bill was crafted by a number of our politicians and lawmakers who either personally experienced, or heard stories from their constituents, regarding financial problems that they have now tried to solve by addressing each situation separately, in a vacuum, then putting all of these together into a bill. Hence the bill doesnt appear to address the true problem, which in my opinion is an almost complete and total lack of regard, and respect for, our current laws and regulations.
Aside from enforcing our current laws and regulations, I have attached copies of changes and clarifications that I believe would help solve our current financial crisis, on a more macro level, as follows:
1. Corporate Governance Whistleblower Reform
2. US Government Reform
3. Know Your Customer and USA PATRIOT Act Clarifications
Sincerely,
Virginia R. Geraghty, CPA