Subject: File No. SR-FINRA-2012-031
From: Dr. Ying Cui
Affiliation: President, Univest Securities

July 20, 2012

FINRA operates as a non-profit, member funded self regulatory organization. FINRA recently released its 2011 financial report which indicated a operating loss of $84,000,000. The financial report also disclosed that the average per employee compensation expenses for 2011 were $174,000. A staggering figure given that the total membership of FINRA has declined by some 11% since 2007. The imposition of new fees without addressing the significant lack of fiscal discipline by FINRA would simply serve to ratify the financially irresponsible manner is which FINRA is currently being operated.

Our business has dropped 70% in pass several years. Only thing we can do is to cut cost. We cut office space more than 60%. Our average salary in 2011 is $20,963, my salary was $29,087. I worked more than 10 hours a day. Some time I really want to drop FINRA membership because it is really not worth my effort any more.

At same time, FINRA doubled fee it charged us. Just know it wants to increase it again. FINRA have to cut the cost and live its own financial means not to increase member fees. You, SEC, please do not help rich people to kill poor people.

Thanks for your consideration!

Dr. Ying Cui, President
Univest Securities