July 13, 2010
Elizabeth M. Murphy
Securities & Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Re: File No. SR-FINRA - 2010-021
Dear Ms. Murphy:
The intent of this filing is laudable, but it is in many ways overbroad and yet in other ways too narrow. The comment letter submitted on July 9, 2010 by the National Association of Independent Broker-Dealers (NAIBD) on the above-entitled matter makes a number of valid points in that regard, and this firm agrees with the views expressed by the NAIBD. We urge the Commission to seriously consider the comments made by the NAIBD.
We also suggest that, should the proposal should be adopted in something resembling its current form, that there be an exception for material provided directly by a firm to FINRA staff on the firm's own premises or personally delivered to FINRA staff on FINRA's premises.
Wulff, Hansen & Co.