April 2, 2005
I believe that the quick and immediate imposition of the disclosure rules called for in File no. S7-06-04 places an unecessary and unfair burden upon independent broker dealers and their affiliate brokers.
Let me be clear, I have no problem with disclosure. Our Branch follows that rule that all transactions with all of our clients include upfront and immediate explanation of fees. Our clients know how we are paid.
What I object to is the SECs inability to understand that our broker dealers are already burdened by the NASDs and the SECs need to subject everyone to a barrage of full range audits, and studies that in fact cause all work to be stopped.
Therefore I am asking for an extension of time before S7-06-04 is forced into effect. Three to six months would be more reasonable.
Thank you for your consideration