Comments on NASD Notice to Members 04-75



In general, I agree with the proposal. Disclosure is always helpful and, probably long overdue. As to the six items you have requested our comments, there are some areas of "over-kill". My comments are as follows, by the numbers:

#1) Other than the five listed disclosures shown in NTM #04-75, I Don't think any more are needed at this time.
#2) I think the obligation already exists. I think the annual audited financials with all footnotes should be sufficient.
#3) Simply NO!!!! Let's not make it any harder for B/Ds to get additional capital.
#4) Fine ---- no additions.
#5) Probably a good "best practice". Let's just leave it at that.
#6) Leave it as is. HISTORICAL PERFORMANCE IS NO GUARANTEE OF FUTURE PERFORMANCE. Seems to me I've read that someplace.