September 29, 2009
As an independent registered representative, I find it disturbing that FINRA may pass its financial burden on to us as advisors. The past year has been hard on many people, and we as advisors are no exception. I personally spent hundreds and hundreds of hours on the phone just to hold the hands of my clients and keep them in the market. I believe we have done our job, both ethically and financially. I personally had to cut spending because of the economic downturn and FINRA`s inability to make the same cuts should not be passed to us. We pay an ample amount of money to practice this profession. Please take this into consideration and thank you for your consideration. Sincerely, Cynthia Iquinto
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 is the root cause of their operating cash flow concerns. It is unfair to burden broker-dealers, financial advisors and their clients, all of whom have all suffered greatly during the recent market downturn, with 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.
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.
FSC Securities Corporation