NAIBD COMMENT 09-22 FINAL
Lisa Roth
June 4, 2009 Marcia E. Asquith Office of the Corporate Secretary FINRA 1735 K Street, N.W. Washington, D.C. 20006 ‐1506 Re: Regulatory Notice 09 ‐22 Personal Securitie s Transactions Dear Ms. Asquith: The National Association of Independent Brokers ‐Dealers, Inc. (NAIBD or the association) was formed in 1979 to positively impact rules, regulations, and legislation by facilitating a consistent, productive relationship be tween industry professionals and regulatory organizations. The organization is national in scope with 350+ Broker ‐Dealer and Industry Associate Members. NAIBD appreciates the opportunity to comment on the proposed rule noted above. We hope that our expres sed views will have constructive value in presenting alternatives, issues and concerns regarding the new rule proposal, and that our responses to specific questions posed in the Regulatory Notice are informative. NAIBD recognizes and appreciates the exten t to which consolidation of the NYSE and NASD rules presents efficiencies and overcomes outdated language. In particular, the proposed elimination of NASD Rule 3050(a)’s requirement regarding account opening due diligence and the elimination of the specifi c supervisory requirements of NYSE Rule 407(b) positively reflect the overall efficiencies resulting from the consolidation of the rulebooks. Notwithstanding this ...