Subject: File No. SR-FINRA-2011-073
From: Chris Melton, Sr.

January 19, 2012

By what form of twisted logic does it appear equitable to anyone that registered broker-dealers pay for the cost of operating the Governmental Accounting Standards Board? Registered broker-dealers are neither governmental entities nor accountants. Will there be similar charges for all vendors doing business with governmental entities? Of course not. Then again, my firm is neither a public company, nor an accounting firm, yet we just received a $2,700 bill from the Public Company Accounting Oversight Board (the PCAOB). Somehow, I doubt we will be getting a discount in that amount from our PCAOB member auditor. It is only fair that our representatives and regulators restrict charges against the broker-dealer community to those items that are directly connected to broker-dealers. The connection to the broker-dealer community in this case is tenuous. Consequently, the fee is an affront to a rational person's sense of fairness.

In the event that the South Dakota Board of Dental Examiners operating account becomes underfunded, will broker-dealers be charged with its operation? After all, dentists have brokerage accounts.