Subject: File No. SR-FINRA-2009-057
From: Suzanne Seay
Affiliation: CFP

September 24, 2009

I am writing to express my concern about a rule proposal that the Financial Industry Regulatory Authority (FINRA) filed with the Securities and Exchange Commission (SEC) concerning a proposal to change FINRA`s regulatory pricing structure by increasing the Personnel Assessment (PA) and Gross Income Assessment (GIA) fees it charges financial advisors and broker-dealers, respectively. In its filing, FINRA indicates that these changes are needed in order to stabilize revenues used to fund FINRA`s regulatory activities.

I believe FINRA`s failure to properly prepare for the inevitable market downturn and their incredible incompetence when auditing Bernard Madoff Securities are two of the root causes of their operating cash flow concerns. Why should we, the honest financial advisors and broker-dealers, have to pay these additional fee assessments. More specifically, the doubling of the PA is simply unjustified by any reasonable calculation of inflation over the five-year period since the last increase in the PA. Additionally, the proposed method of calculation for the GIA will only heighten the disproportionate regulatory cost borne by independent broker-dealers, financial advisors, and their clients. We are the ones in the trenches working with middle income clients. FINRA (formerly the NASD) did a poor job of supervising as well as managing their cash flow. Don`t give them a "bailout" by penalizing us.

I request that the SEC reevaluate FINRA`s rule proposal to increase the PA and GIA it assess on its members and request that FINRA develop an alternative approach to fund raising in an effort to sustain itself.


Suzanne Seay
Royal Alliance