March 3, 2006
This proposed policy (IM-3060) is an extensive reach into the
broker-client relationship and is clearly "legislating morality". My
request would be that this Interpretive Material be dropped entirely and
that we rely on the client firms to be responsible for what gifts and
gratuities they will allow their employees to accept. Each brokerage
firm should be allowed to make the decision as to what expenses are
reasonable from their employess for the pursuit of their business.
There should be no additional NASD paper trail for this activity above
and beyond the current requirement for corporate reporting.
Thank you for your attention to this commentary.
John W. Goodwin
Goodwin Browning & Luna Securities, Inc.