June 21, 2007
To Whom It May Concern:
Fintegra is submitting this comment in support of the proposed NASD Rule amendments to Rule 1120, Rule 1150, IM 3001-2 and Rule 3520, and the approval of new NASD Rule 1160.
SUPPORT FOR THE RULE(S) AMENDMENTS AND CHANGE
Fintegra supports the NASDs evaluation of the benefits broker-dealers would gain from the above rule amendments and changes. Valuable resources and time can be needlessly wasted for many firms, large and small alike, in logging into the NASD Contact System every quarter to simply respond that no executive or contact changes have taken place. By simply requiring an annual review and a report as required stance, firms will be able to free up resources and operate more efficiently.
Fintegra also agrees with the NASDs evaluation of the effectiveness of the annual review and only reporting any contact changes as they occur. Fintegra does not see any negative impact in the integrity or accuracy of the contact information the NASD currently has via the NASD Contact System. An annual review and contact person change initiated reporting should be more than sufficient for the NASDs intended purpose for maintaining that information.
RECOMMENDED AMENDMENT TO NASD RULE 1160
Fintegra would make one suggested change. NASD Rule 1160(b) requires every broker-dealer to update its required contact information within 17 business days after the end of each calendar year.
NASD Rule 1160(c) however requires that every broker-dealer comply with ad hoc NASD requests for information promptly, but in any event not later than 15 days following the request
For ease of complying with the rule, Fintegra recommends that NASD Rule 1160(b) be amended by changing the time of compliance to 15 days so as to simplify adherence to the rule. Fintegra does not see any justification in or benefit of differentiating the time lines of compliance between the yearly review and a NASD ad hoc request.
Otherwise, Fintegra stands in support of the NASD proposal. Thank you for your time and consideration.
Kenneth M. Cherrier, JD
Chief Compliance Officer
Fintegra Financial Solutions