April 1, 2005
To the U. S. Securities and Exchange Commission:
Please extend the deadline for your proposed ruling on point of sale and confirmation disclosures, File number S7-06-04, for at least a full 30 days, especially considering that the notice of the 30 day comment period on the ruling beginning March 1st, was not received by FSI members until March 7th, therefore there was no de facto 30 day notice. If public perception of the ethics of the SEC matters, then this needs to be addressed in a sincere and ethical way.
It seems to me that there are substantial unintended consequences of this proposed regulation, for those of us associated with independent broker/dealers. The potential for extremely onerous and costly expenses may limit the number of covered securities offered for sale, which is certainly not in the best interest of the public. For the SEC to be perceived as creating circumstances that limit choices and favor certain securities or investment companies over others should not be one of the intended consequences.
For us to reach this point in such a discussion is unfortunate and embarrasing. Please try to assume the best, not the worst until proven otherwise and extend the deadline. Thank you for your thoughtful consideration.
Daniel T. Griner