I am responding to the request for comment in April 2005 Notice to Members
on the proposed advertising filing requirement of all TV, video and radio
advertising of 15 seconds or longer. I agree that there have been media
advertisements that are questionable, if not flagrant violations of the
advertising rules which could have been stopped before it reached the public
if this rule were in place. There is a need for a change in this area. I
hope that you will consider making the final requirement less broad,
excluding generic ads that just highlight the firm or that do not mention
specific product features. My firm uses 30-60 second generic radio ads to
attract new employees and/or clients. We basically use the ads for name
recognition within our community and do not use them for any specific
product or department. I would hope that these type ads would be exempt
from the 10 day prior filing requirement and that the advertising principal
could sign off on these generic ads.
Thank you for your consideration of my comments.
Jennifer Carty Scola
Chief Operating Officer, Executive VP
Carty & Company, Inc.