Comments on NASD Notice to Members 04-45

Dear Ms. Barbara Sweeney:
I embrace nearly every required change foisted on me either by government entities or the companies I represent because most of those changes can be used for the better. We typically embrace change to distinquish ourselves from the others. Our practice has always adhered to both the law and the highest ethical standards of our profession.

However, I must speak out when the regulations become unrelenting. Is there a cost too high in order to best serve our clients? Frankly, the answer is YES.


With my primary company we have just adopted the use of 16 pages booklets and newly revised Investor Account Forms to accompany the booklet, to appease company and government regulators. In my opinion the booklet is excellent. The Investor Account Form is the second revised form we have used this calendar year.


I cannot image the rock and the hard place regulators find themselves in. But please know that every rock and hard place you find yourself in adds that much more regulation I must endure again reducing revenues and driving up the cost of doing business.


Please back off the producer and lean harder on the B/Ds.


Thank you for your consideration in this matter.



Steven Brooks
3400 Buttonwood Drive, Suite A
Columbia, MO 65201