As an intermittent user of BrokerCheck, I appreciate the ability to obtain information on NASD members. I would like to comment, however, on the four questions posed within Notice to Members 03-76, dated December 2003.
Should the current system be replaced? Yes, but not in the manner prescribed within the Notice.
What are alternative solutions? Provided direct, yet limited, access to the NASD's records via the internet. A good example of such an approach is the "Agent Database" function on the Texas Department of Insurance Web site (http://www.texasonline.state.tx.us/NASApp/tdi/TdiARManager). It negates the need for granting, tracking, and using codes for what is essentially public information.
How long should the access code remain valid? N/A if #2 is adopted.
What about additional protections? If #2 is adopted, the NASD will have to devise a system to ensure only limited portions of each member's records are available through the internet access point, as is no doubt done currently.
Thank you for the opportunity to comment on the proposed change.
S. Lynn Carlson
Texas OSJ Manager
Farmers Financial Solutions, LLC
(512) 238-4086 (office)
(512) 658-1265 (cell)
(801) 437-3939 (fax)