Comments on NASD Notice to Members 05-27

To Whom It May Concern:

 

Fintegra, a NASD member B/D with the NASD with 200 RR's and over 2 Billion under management, is in full support of the NASD's proposed amendment to NASD Rule 2211 as long as the required principal review prior to use material (correspondence to 25 or more current clients) is not required to be filed with the NASD under the advertising and sales literature rules.

 

Fintegra's stance is that the $100 fee ($500 for expedited review) is just too high for the current system and format requiring filing.  Therefore, adding any additional rules requiring filings with the NASD Ad Review Department would be overly burdensome to B/D's.

 

Fintegra takes the stance that the cost for filing ($100/$500 per piece) far outweighs any benefit derived from NASD review of the piece.

 

If you have any specific questions, please contact me at the numbers below.  I thank you for your time.

 

Kenneth M. Cherrier, JD, FLMI, AIRC, AIAA, ACS

Chief Compliance Officer

 

Fintegra, LLC

6120 Earle Brown Drive #550

Minneapolis, MN  55430

Phone #: 763-585-0503

Fax #: 763-585-0509

Email: Kenc@Fintegra.com