Comments on Regulatory Notice 08-20


I cannot believe that FINRA has waited this long to finally figure out that a written complaint by Statement of Claim is a complaint just like a letter. An absurd condition has existed. Some very bad brokers who have done terrible things continue to have a clean record even though their firms have paid millions to victims of the broker's misconduct.

I only represent claimants, and exclusively bring FINRA claims, mostly through the Boca regionaI office, and I have never written a comment to FINRA until now.

I never name the individual brokers anymore, because I was tired of getting uncollectable awards against individuals and chasing them through bankruptcy courts, and did not appreciate being in a cross-fire of multiple respondent attorneys. Given respondeat superior, there is no good reason to name an individual agent at all. For FINRA to have considered a Statement of Claim itemizing misconduct by an agent as "not a complaint" was disgraceful. Finally, somebody at FINRA "gets it."

Attorney Richard A. Stephens
Boca Raton, FL