Subject: SR-FINRA-2020-041
From: Richard Carlesco
Affiliation:

Dec. 15, 2020



Yet another example of FINRA dumping on small firms trying desperately to hang on with the throng of new regulations that are burying small firms across this country. They are selling out in droves. Try to tell me that the large firms are not running the show.
 
I have 70 reps 7 of which where at expelled firms during their career. 
3 have no disclosures, just had the unlucky experience of being at that firm.
2 have 1 customer complaint. In our current environment where lawyers are recruiting clients to arbitrate against reps and firms, due to no fault of their own. Simply because they know we will settle because the cost to go to arbitration is so expense.
1 has 1 financial disclosure, medical losses.
1 has 3 disclosures. He could be a discussion.
 
This rule will have awful unintended consequences for small firms. Increased costs to defend and reporting.
 
Instead FINRA should move against these so called rogue firms, instead of placing more burdens on already stretched small firms.
 
You can’t tell me that FINRA is moving to eliminate small firms simply because they are not profitable enough for FINRA to regulate. (They can’t fine them enough)
 
 
Richard J. Carlesco Jr.,  CEO
 
Choose to Judge by the Content of Someones Character
 
IBN Financial Services, Inc.
404 Old Liverpool Rd.
Liverpool, NY 13088
Mailing Address
PO Box 2365
Liverpool, NY 13089
 
http://www.ibnfinancialservices.com