Subject: SR-FINRA-2022-024: WebForm Comments from Douglas W OConnell
From: Douglas W OConnell
Affiliation: Certified Financial Planner

Aug. 23, 2022

 August 23, 2022

 Basic premise of our legal system is \"innocent until proven guilty\". FINRA Brokercheck lists client issues/concerns/complaints without any due legal course. Brokers post erroneous and libel comments on departing brokers to discourage other advisors from leaving. Brokers post client complaints toward internal processes on advisors U4 - even when the client specifically does not mention the advisor or specifically indicates the complaint is not at the advisor but at the broker's process.

The current system can cost the advisor $5,000 or more just to have a hearing on expungement - its way to expensive. The proposed system basically is even worse making it very difficult to remove spurious brokercheck disputes. Meanwhile, states do zip to regulate 1000s of insurance agents selling index annuities as the investment panacea for retirees and estate planning. Other than MA, NY and FL - most states do little to regulate insurance or securities - makes no sense to involve them too.