Sep. 8, 2023
I support S7-11-23 and want to see these changes enacted immediately. Broker-Dealers should not be allowed the ability to mismanage customer funds that benefit the Broker dealer instead of protecting their customers. Broker-Dealers need to be held accountable for minimizing the risk to their customers, requiring daily computations of total credits vs debits (net cashed owed) will greatly reduce the risk that customers are typically unaware is there. Investors expect their brokers to operate in a manner that is of the best interest of the customer, not what allows for the brokers to leverage customers funds in a way that benefit the Broker and puts the customers at risk. I do not agree or support any of the other reasonable alternatives" as they fail to have clear guidelines and consideration of these further delay the SEC's ability to regulate Broker-Dealers. Counter arguments to this proposal may include that daily computations or the timing requirments of depositing funds to meet reserve minimums create additional administrative costs to the Broker. These costs must be assumed by the broker to do business and should not be considered as a reason to not pass this proposal. I also believe all broker-dealers, not just those exceeding $250m credits, should be required to complete daily computations. However I find it acceptable to start with these larger broker-dealers to establish a base line that can be used to study the effectiveness of the proposed rule. Thank you, J.R. Rothwell