Subject: File No. SR-NASD-2004-121
From: Colon Brown
Affiliation: Brown & Brown Securities, Inc.
September 10, 2004
RE: File Number SR-NASD-2004-121
To Whom It May Concern:
Brown & Brown Securities, Inc. is supportive of efforts to equip the NASD and the SEC with sufficient rules and attendant sanctions to regulate and punish behavior which is contrary to the best interest of the investing public. It is our belief, however, that no amount of additional rules will deter those endowed with dishonest motives. Also, while increasing the severity of sanctions for minor or technical violations may make life more efficient for regulators, such actions place additional undue burdens on many practioners who are trying to deliver useful services to investors.
Also, regulators must be careful when attempting to increase the severity of sanctions, especially fines, not to be perceived as morphing from a regulator into a revenue center.
Finally we wonder if the regulators have the resources to be so concerned about "minor and technical violations."