From: Frank P. L. Minard
Sent: January 12, 2016
Subject: File No. SR-FINRA-2015-054

Robert W. Errett
Deputy Secretary
Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-1090

File Number: SR-FINRA-2015-054.  [By electronic submission]

Dear Mr. Errett,

My firm,. XT Capital Partners, is a FINRA member specializing in Third Party Marketing focused on raising assets for Alternative Investment Firms primarily from Institutional Investors with whom we have interacted for over 40 years. I am a member of the Third Party Marketer’s Association (3PM) and serve on the Board. I have had an opportunity to review 3PM’s comprehensive comments regarding the rule set proposed by SR-FINRA-2015-054 for Capital Acquisition Broker (CAB).  I urge the SEC and FINRA to carefully consider 3PM's thoughtful and informed commentary, which has earned my strong support.





Frank P. L. Minard
Managing Partner
XT Capital Partners, LLC 
311 Post Road East

Westport, CT 06880