Subject: File No. SR-FINRA-2009-008
From: Steven M. Sherman, Esq.
I write in support of the proposed rule relating to changes in Forms U4 and U5.
I am an attorney with 20 years of securities law experience. I have represented investors, investment professionals and privately held companies in a variety of proceedings, including industry-sponsored arbitration, court litigation, regulatory proceedings and in certain transactional matters. No matter from which direction one approaches any of the foregoing subspecialties of securities law, one precept which
is beyond debate is that securities laws are premised on full disclosure. All participants in our securities industry should therefore welcome the opportunity to make full disclosure of all facts a reasonable investor is likely to consider material in making an investment decision. These material facts also include the regulatory, compliance and legal history of a person providing investment advice, including stockbrokers.
If the guardians of our markets wish to rebuild trust and confidence in our securities markets and institutions, then implement rules and procedures to mandate full disclosure. Not only will this allow consumers the opportunity to become better informed, it will also benefit the majority of financial professional that conduct themselves in accordance with the trust they have earned.
I urge the prompt approval of this proposal.
Respectfully submitted,
Steven M. Sherman
Law Offices of Steven M. Sherman