Aug. 31, 2022
To Whom It May Concern, Having read through a good portion of these proposed rule changes for filing an expungement request, my overall impression is that it's an attempt to eliminate expungement requests by making it so difficult and expensive that no financial advisor will ever attempt to try. These proposed rule changes, to my mind, are totally egregious. While I readily and heartily agree that there is a need to police financial advisors and eliminate the truly “bad apples”, these proposed rule changes go way too far. I'm all for protecting the public, but there has to be a reasonable way for a well-intended financial advisor who makes a mistake or two to get his/her good name and reputation back. Isn't it enough to have the “Broker Check” link on every independent financial advisors webpage? Of course it only appears on the webpage for independent financial advisors. It doesn't appear on the webpages of the national wire houses, so how is that fair? The national wire houses shield their financial advisors so that the average consumer can't look them up. On that alone it's in an uneven playing field so to speak. Limiting the time frame for expungement to three years and calling in state regulators to participate now only increases the expense of filing for expungement, but forces the financial advisor involved to suffer from a bad reputation the rest of his professional life. Can the same be said for doctors and lawyers? If financial advisors are held to be as professional as doctors and lawyers, then why isn't there the equivalent of “Broker Check” for doctors and lawyers? Reading over these proposed rule changes suggest to me that it's very one-sided and I'm opposed to these rule changes as a consequence. If there can't be some way that a financial advisor can regain a good reputation than we financial advisors might as well quit using our Series 7 licenses and just become RIA's. Michael A. Neal Financial Advisor M. A. NEAL Financial Services 209 North Main Street Suite 7 Horseheads, New York 14845 Office # (607) 737-5599 / (800) 504-6440 Email: www.maneal.com