From: Jay Lanstein
To Whom It May Concern:
I am writing on behalf of Cantella & Co., Inc. While we are defined by FINRA as a mid-sized firm, we are very much a small business. The current 0.25% assessment makes a very substantial impact on firms such as ours. We believe the assessment should be lowered as soon as the SIPC fund reaches its target balance, rather than waiting potentially a full year. The proposed reductions should in fact be further reduced.
We believe these changes will benefit members and will not present any additional risk to the SIPC fund or investors. SIPC has the ability under the current proposal to immediately raise assessments when warranted. Further, its backstop is to borrow from the Treasury, which provides a second layer of protection. Continuing to extract unnecessary fees from the industry only presents a financial burden to customers. While our firm does not pass along the assessment to customers, some other firms do. Thus, in some cases, these unnecessary costs are being directly passed on to the very same investors the proposal seeks to protect.
Thank you for your consideration.