April 4, 2005
I am requesting an extended comment period on SEC Proposal on Point of Sale & Confirmation Disclosures.
The proposed new rules File number S7-06-04 includes adoption of proposed new rules that may have substantial and unintended consequences for independent broker/dealers and their registered representatives. Of primary concern is that complying with the proposed rules - principally the creation and maintenance of the point of sale disclosure - will be so extremely burdensome and costly that the number of approved Securities will be reduced significantly.
The aggressive April 4 deadline for comments is not enough time for a full review of the facts and requirments and effects on our Business. If passed, this proposal could result in a major impact on the entire industry.