Comments on Notice to Members 07-12
In my opinion you have made this way to wordy and it should be simplified.
Some suggestions for doing so:
A main office is a main office, is a main office, is a main office.
Wherever final supervisory authority rests is (should be) designated the MAIN OFFICE.
If personnel in the main office take ultimate responsibility for suitability and review of all trades, and all new account apps, then this is the office that should be held responsible for anything Examiners want/need to look at.
If the administrative HOME OFFICE (which does not need to be deifined in regs) houses no supervisory functions, it is not the MAIN OFFICE. Thr regs are (should be) concerned with the main supervisory office.
If the MAIN OFFICE delegates any of above to a SUPERVISORY OFFICE, then an annual internal exam may be required.
The concept of Limited supervisory office doesn't make sense to me. Why, if a SUPERVISORY OFFICE is going to be responsible for all activity is there a need for another office definition? These supervisory people have responsibility for the reps activity. Leave it up to them to decide how often to talk with and visit with the reps, whether they are physically located in their location, working from another office (probably one man in a strip mall, etc.), or out of their home (the case with most small b/d reps).
A rule dictating a physical visit to one man offices, if all applications and new acct forms are in the supervisory office, isn't going to accomplish anything, in my opinion. Tell me of an occasion that lack of visiting a one man office has caused harm, and I will be educated. You may site cases of fraud. But, if someone intends to commit fraud, I doubt a physical visit will detect it.
If a rep working from home or an office mails all apps to the supervisory office (application way), or calls in introduced trades to the supervisory office, I can't see the sense in defining this location as a branch of any kind. Why do you care to know? These reps are treated and communicated with the same as if they had a desk down the hall by the small b/ds I am familiar with.
Why is important for all Ed Jones offices to be registered, for example?
They are highly supervised. How does it help examiners to know the physical location of these offices? How is the public protected by having these offices registered, and charged another fee?
Please, folks, think, "how does this rule protect the public" as you write.
and use as few words as possible. The rules and regs have already gotten so large that VERY few people have time to read them, and fewer understand them. You delegate writing supervisory proceedures to the b/d. But, instead of making it so we can use fewer words that can be used for training, you are forcing us to add words to your words to cover any possibilities. Reps will not (don't kid yourself) read supervisory manuals this large, any more than the public will read a prospectus!