July 29, 2015
Thank you for the opportunity to comment on this rule proposal. I am an attorney who focuses my practice on representing investors who have been wronged by their financial advisor and securities brokerage firm.
I support the rule proposal to require a BrokerCheck links on firm websites. Investors should have all the necessary information available to them in order to make informed decisions. Relevant information about their financial advisors background is highly relevant and should be readily available to investors. This rule will help promote investors awareness of this tool.
However, this rule should go further. It would not be much of a financial burden to require firms to add the BrokerCheck links to emails and account statements. Most account statements are currently littered with various disclosures, so it would not be burdensome to include the BrokerCheck website on the statement. However, it would be prudent to make the BrokerCheck link readily apparent, such as by setting it apart from the usual disclosure information on the statement. Additionally, the burden of putting the link on emails is minimal, which can easily be accomplished by adding such in the signature block of emails, which most advisors already use.
While the rule proposal is a step in the right direction, investors should be able to view all relevant information that is available in the CRD system about their advisor. BrokerCheck excludes certain information that is currently available on the CRD system, such as tax liens or bankruptcies that were filed more than 10 years ago, or how many times their advisor failed their examinations. This information can be accessed by the public, but only through more complicated processes, depending on which state they request it from. Providing this already-public information on BrokerCheck simply makes sense.
Thank you again for the opportunity to comment on this proposal.
Regards,
David Neuman