From: gfrazier@finsvcs.com
Sent: Friday, January 30, 2004 4:43 PM
To: rule-comments@sec.gov
Subject: file#SR-NASD-2003-104 Proposed NASD Rule Change re: Definition
of Branch Office

Dear     Secretary: 
Dear Madam/Gentleman:

The NASD's proposal to revise the definition "Branch Office" in Rule 3010(g)(2) is
harmful to me as an NASD Licensed Professional and my customers for the following
reasons:

1)  Small offices are not able to take on more expenses. 

2)  The additional administrative requirements will be difficult to meet

3)  Many small offices will be forced to close.  Thereby, denying some customers 
Mutual Funds and other Variable Products so important to their overall financial 
plan

4)  The NASD action is not necessary in that they neither have the money nor the 
man power necessary to monitor all the remaining small offices

5)  The change is patently unfair to insurance broker dealers because most of 
their representatives practice full financial planning typically in one, two 
or three practitioner offices

6)  A decrease in the number of locations and offices will have a negative impact 
on many consumers and make it more difficult to secure the help and advice they 
want and need.

Please reject the NASD proposal 3010(g)(2)(E)to revise the definitions of "Branch 
Office" and keep the current definition.  At the very minimum significantly 
increase the number  of permitted transactions and waive the filing fee for 
any small offices that become a "Branch Office" by your allowing the NASD 
proposal to become a regulation.

Thank you for your consideration.

 



Sincerely, 


Gene Imke
11205 N. May 
Oklahoma City, OK 73120