September 24, 2009
The mere thought that FINRA would consider increasing fees to members by 100% at a time when most Broker-Dealersare struggling to keep their financial heads above water is indicative of a self-regulatory organization out of touch with its members and definitely insensitive to economic realities.
Our company is in the process of providing its budget to our parent company and we have been asked to reduce expenses substantially in 2010. This proposed change to the exisitng fee structure would impact us so severely, doublihg our costs, that it seriously jeopardizes our survivability in today's market.
Over the past three years FINRA has given every indication that it cares only about its own survival without any regard for its members financial situation. At the very least, this proposal should be mitigated: it should be delayed by one year and it should also include increases more aligned with reality and inflation: 10% - 15% increases, not an absurd figure of 100%. If it is a ploy to ask for 100% and then settle for 50%, I suggest FINRA administrators take a 25% pay reduction to lower their expenses. Don't kill off members to keep the SRO alive.
This firm strongly opposes any fee increase at this time.